&EPA
United States
Environmental Protection
Agency
Enforcement and
Compliance Assurance
(2221-A)
EPA310-R-00-003
September 2000
Profile of the Agricultural
Chemical, Pesticide, and
Fertilizer Industry
J.I. n
EPA Office of Compliance Sector Notebook Project
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Agricultural Chemical Industry
Sector Notebook Project
EPA Office of Compliance Sector Notebook Project
Profile of the Agricultural Chemical, Pesticide, and
Fertilizer Industry
Sebtemper 2000
Office of Compliance
Office of Enforcement and Compliance Assurance
United States Environmental Protection Agency
1200 Pennsylvania Avenue, NW (MC 2221-A)
Washington, DC 20460
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Agricultural Chemical Industry
Sector Notebook Project
This report is one in a series of volumes published by the United States Environmental Protection
Agency (EPA) to provide information of general interest regarding environmental issues associated
with specific industrial sectors. The documents were developed under contract by Abt Associates
(Cambridge, MA), Science Applications International Corporation (McLean, VA), and Booz-Allen
& Hamilton, Inc. (McLean, VA). A listing of available Sector Notebooks is included on the
following page.
Obtaining copies:
Electronic versions of all sector notebooks are available via Internet on the Enviro$en$e World
Wide Web at www.epa.gov/oeca/sector. Enviro$en$e is a free, public, environmental exchange
system operated by EP As Office of Enforcement and Compliance Assurance and Office of Research
and Development. The Network allows regulators, the regulated community, technical experts, and
the general public to share information regarding: pollution prevention and innovative technologies;
environmental enforcement and compliance assistance; laws, executive orders, regulations, and
policies; points of contact for services and equipment; and other related topics. The Network
welcomes receipt of environmental messages, information, and data from any public or private
person or organization. Direct technical questions to the "Feedback" button on the bottom of the
web page.
Purchase printed bound copies from the Government Printing Office (GPO) by consulting the
order form at the back of this document or order via the Internet by visiting the on-line GPO Sales
Product Catalog at https://orders.access.gpo.gov/su_docs/sale/prf/prf.html. Search using the exact
title of the document "Profile of the XXXX Industry" or simply "Sector Notebook." When ordering,
use the GPO document number found in the order form at the back of this document.
Complimentary volumes are available to certain groups or subscribers, including public and
academic libraries; federal, state, tribal, and local governments; and the media from EP A's National
Service Center for Environmental Publications at (800) 490-9198. When ordering, use the EPA
publication number found on the following page.
The Sector Notebooks were developed by the EPA's Office of Compliance. Direct general questions
about the Sector Notebook Project to:
Seth Heminway, Coordinator, Sector Notebook Project
US EPA Office of Compliance
1200 Pennsylvania Avenue, NW (2223-A)
Washington, DC 20460
(202) 564-7017
For further information, and for answers to questions pertaining to these documents, please refer to
the contact names listed on the following page.
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Sector Notebook Project
SECTOR NOTEBOOK CONTACTS
Questions and comments regarding the individual documents should be directed to the specialists listed
below. See the Notebook web page at: www.epa.gov/oeca/secior for the most recent titles and staff
contacts.
EPA Publication
Number
EPA/310-R-95-001.
EPA/310-R-95-002.
EPA/310-R-95-003.
EPA/310-R-95-004.
EPA/310-R-95-005.
EPA/310-R-95-006.
EPA/310-R-95-007.
EPA/310-R-95-008.
EPA/310-R-95-009.
EPA/310-R-95-010.
EPA/310-R-95-011.
EPA/310-R-95-012.
EPA/310-R-95-013.
EPA/310-R-95-014.
EPA/310-R-95-015.
EPA/310-R-95-016.
EPA/310-R-95-017.
EPA/310-R-95-018.
EPA/310-R-97-001.
EPA/310-R-97-002.
EPA/310-R-97-003.
EPA/310-R-97-004.
EPA/310-R-97-005.
EPA/310-R-97-006,
EPA/310-R-97-007.
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
R-97-008.
R-97-009.
•R-98-001.
•R-97-010.
•R-99-006.
•R-00-003.
EPA/310-R-OO-OOl
EPA/310-R-00-002
Industry
Profile of the Dry Cleaning Industry
Profile of the Electronics and Computer Industry*
Profile of the Wood Furniture and Fixtures Industry
Profile of the Inorganic Chemical Industry*
Profile of the Iron and Steel Industry
Profile of the Lumber and Wood Products Industry
Profile of the Fabricated Metal Products Industry*
Profile of the Metal Mining Industry
Profile of the Motor Vehicle Assembly Industry
Profile of the Nonferrous Metals Industry
Profile of the Non-Fuel, Non-Metal Mining Industry
Profile of the Organic Chemical Industry *
Profile of the Petroleum Refining Industry
Profile of the Printing Industry
Profile of the Pulp and Paper Industry
Profile of the Rubber and Plastic industry
Profile of the Stone, Clay, Glass, and Concrete Ind.
Profile of the Transportation Equip. Cleaning Ind.
Profile of the Air Transportation Industry
Profile of the Ground Transportation Industry
Profile of the Water Transportation Industry
Profile of the Metal Casting Industry
Profile of the Pharmaceuticals Industry
Profile of the Plastic Resin and Man-made Fiber Ind.
Profile of the Fossil Fuel Electric Power Generation
Industry
Profile of the Shipbuilding and Repair Industry
Profile of the Textile Industry
Profile of the Aerospace Industry
Sector Notebook Data Refresh-1997 **
Profile of the Oil and Gas Extraction Industry
Profile of the Agricultural Chemical, Pesticide, and
Fertilizer Industry
Profile of the Agricultural Crop Production Industry
Profile of the Agricultural Livestock Production
Industry
Contact Phone (202)
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Maria Malave
Anthony Raia
Debbie Thomas
Rob Lischinsky
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Seth Heminway
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Steve Hoover
Emily Chow
Sally Sasnett
Rafael Sanchez
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-5027
564-6045
564-5041
564-2628
564-7067
564-7003
564-7072
564-7017
564-2310
564-7013
564-7057
564-7057
564-7057
564-7057
564-7007
564-7071
564-7074
564-7028
Anthony Raia
Anthony Raia
Seth Heminway
Dan Chadwick
Michelle Yaras
Ginah Mortensen
Ginah Mortensen
564-6045
564-2310
564-6045
564-7017
564-7054
564-4153
913-551-5211
913-551-5211
EPA/310-R-99-001.
Government Series
Profile of Local Government Operations
564-2310
* Spanish translations available.
** This document revises compliance, enforcement, and toxic release inventory data for all profiles published in
1995.
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TABLE OF CONTENTS
LIST OF FIGURES v
LIST OF TABLES . vi
LIST OF ACRONYMS viii
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
LA. Summary of the Sector Notebook Project - .1
I.B. Additional Information . 2 '
II. INTRODUCTION TO THE AGRICULTURAL CHEMICAL INDUSTRY 3
II. A. Introduction, Background, and Scope of the Notebook 3
II.B. Characterization of the Fertilizer, Pesticide, and Agricultural Chemical Industry .. 4
II.B.l. Product Characterization 5
II.B.2. Industry Size and Geographic Distribution 19
II.B.3. Economic Trends 24
III. INDUSTRIAL PROCESS DESCRIPTION .27
III.A. Nitrogenous Fertilizers 27
III.A.l. Synthetic Ammonia 27
III.A.2. Nitric Acid 32
III.A.3. Ammonium Nitrate and Urea 36
III.B. Phosphatic Fertilizers 40
III.B.l. Phosphoric Acid (Wet Process) 40
III.B.2. Ammonium Phosphate 43
III.B.3. Normal Superphosphate 44
III.B.4. Triple Superphosphate 47
III.C. Fertilizer Mixing 49
III.D. Pesticide Formulating and Preparing Processes . .51
III.D.l. Liquid Formulating and Packaging 52
III.D.2. Dry Formulating and Packaging 5-3
III.D.3. Aerosol Packaging 55
III.D.4. Pressurized Gas Formulating and Packaging 56
III.D.5. Repackaging 56
III.E. Raw Material Inputs and Pollution Outputs 57
III.E.l. Fertilizers 57
III.E.2. Pesticide Formulating, Packaging, and Repackaging 66
III.F. Management of Chemicals in Wastestream 71
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IV. CHEMICAL RELEASE AND TRANSFER PROFILE 75
IV.A. EPA Toxic Release Inventory for the Fertilizer, Pesticide, and Agricultural
Chemical Industry .- 78
IV.B. Summary of Selected Chemicals Released 92
IV.C. Other Data Sources ..96
IV.D. Comparison of Toxic Release Inventory Between Selected Industries 98
V. POLLUTION PREVENTION OPPORTUNITIES . .101
V.A. Equipment Cleaning 105
V.B. Process Changes 109
V.C. Good Housekeeping Ill
VI. Summary of Applicable Federal Statutes and Regulations 117
VI.A. General Description of Major Statutes 117
Imports and Exports 119
VLB. Industry Specific Requirements 135
VI.C. State Requirements 144
VI.D. Pending and Proposed Regulatory Requirements 145
VII. COMPLIANCE AND ENFORCEMENT HISTORY 149
VILA. Fertilizer, Pesticide, and Agricultural Chemical Industry Compliance History 153
VII.B. Comparison of Enforcement Activity Between Selected Industries ......... 155
VII.C. Review of Major Legal Actions 160
VII.C.l. Review of Major Cases 160
VII.C.2. Supplementary Environmental Projects (SEPs) 164
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES 165
VIII.A. Sector-Related Environmental Programs and Activities 165
VIII.B. EPA Voluntary Programs 167
VIII.C. Trade Association/Industry Sponsored Activity 173
VIII.C.1. Trade Associations 173
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS 181
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LIST OF FIGURES
Figure 1: Number of Facilities and Value of Shipments of the Fertilizer, Pesticide, and
Agricultural Chemical Manufacturing Industry 6
Figure 2: Product Distribution for SIC 2873, Nitrogenous Fertilizers 9
Figure 3: Product Distribution for SIC 2874, Phosphorous Fertilizers 11
Figure 4: Product Distribution for SIC 2879, Pesticides and Miscellaneous Agricultural
Chemicals 16
Figure 5: Geographic Distribution of the Fertilizer Industry (SIC 2873, 2874, 2875) 20
Figure 6: Geographic Distribution of the Pesticide Formulating and Miscellaneous
Agrichemical Formulating Facilities (SIC 2879) 22
Figure 7: Typical Process of Ammonia Synthesis 29
Figure 8: Typical Process of Dual-Stage, Weak Nitric Acid Production 35
Figure 9: Typical Process Diagram of High Strength Nitric Acid Production 36
Figure 10: Typical Process for Ammonium Nitrate and Urea Manufacturing 39
Figure 11: Typical Process of a Wet Process Dihydrate Phosphoric Acid Plant 42
Figure 12: Typical Vacuum Evaporator Process 42
Figure 13: Simplified Process Flow Diagram of Diammnonium Phosphate Production 44
Figure 14: Typical Process for Normal Superphosphate Manufacturing ...... 46
Figure 15: Typical Process for Triple Superphosphate : .48
Figure 16: Typical Process for Liquid Formulating 53
Figure 17: Typical Process for Dry Formulating 55
Figure 18: Raw Material Flowchart for Principal Fertilizer Materials 57
Figure 19: Summary of 1995 TRI Releases and Transfers by Industry 99
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LIST OF TABLES
Table 1: Nitrogenous Fertilizer Products (SIC 2873) 7
Table 2: Phosphatic Fertilizer Products (SIC 2874) 9
Table 3: 1990 Direct vs Mixed Application of Primary Fertilizer Nutrients 12
Table 4: SIC 2879 Pesticides and Miscellaneous Agricultural Chemicals, List of Products 13
Table 5: Establishment Counts Based on Product Type 18
Table 6: Facility Size Distribution for the Fertilizer, Pesticide, and Agricultural Chemical
Manufacturing Industry 19
Table 7: States with the Largest Number of Fertilizer Manufacturing Facilities 21
Table 8: Top United States Agricultural Chemical Companies 23
Table 9: Fertilizer Materials Used in Bulk Blends 49
Table 10: Approximate Quantities of Most Commonly Used Conventional Pesticides in United
States Agricultural Crop Production 67
Table 11-: Summary of Potential Pollution Outputs for the Agricultural Chemical Industry .. 70
Table 12: Source Reduction and Recycling Activity for the Fertilizer Industry as Reported
within TRI 72
Table 13: Source Reduction and Recycling Activity for the Pesticide and Miscellaneous
Agricultural Chemicals Industry 73
Table 14: 1996 TRI Releases for Agricultural Chemicals Facilities (SICs 2873,2874,2875)
by Number of Facilities Reporting (Releases reported in pounds/year) 81
Table 15: 1996 TRI Transfers for Agricultural Chemicals Facilities (SICs 2873,2874,2875)
by Number and Facilities Reporting (Transfers reported in pounds/year) 82
Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of
Facilities Reporting (Releases reported in pounds/year) 83
Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)
by Number and Facilities Reporting (Transfers reported in pounds/year) 86
Table 18: Top 10 TRI Releasing Fertilizer Manufacturing and Mixing Facilities
(SIC 2873, 2874, 2875) 90
Table 19: Top 10 TRI Releasing Facilities Reporting Fertilizer Manufacturing and Mixing SIC
Codes 90
Table 20: Top 10 TRI Releasing Pesticide and Miscellaneous Agricultural Chemicals Facilities
(SIC2879) 91
Table 21: Top 10 TRI Releasing Facilities Reporting Pesticide and Miscellaneous Agricultural
Chemicals SIC Codes 91
Table 22: Air Pollutant Releases by Industry Sector (tons/year) 97
Table 23: 1995 Toxics Release Inventory Data for Selected Industries 100
Table 24: Waste Minimization Methods for the Fertilizer, Pesticide, and Agricultural Chemical
Industry 104
Table 25: Five-Year Enforcement and Compliance Summary for the Fertilizer, Pesticide, and
Agricultural Chemical Industry 154
Table 26: Five-Year Enforcement and Compliance Summary for Selected Industries 156
Table 27: One-Year Enforcement and Compliance Summary for Selected Industries 157
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Table 28: Five-Year Inspection and Enforcement Summary by Statute for
Selected Industries 158
Table 29: One-Year Inspection and Enforcement Summary by Statute for
Selected Industries 159
Table 30: Fertilizer, Pesticide, and Agricultural Ghemical Industry Participation in the 33/50
Program '. 169
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LIST OF ACRONYMS
AAEA American Agricultural Economics Association
AAPCO Association of American Pesticide Control Officials
AAPFCO Association of American Plant Food Control Officials
ACPA American Crop Protection Association
AFS AIRS Facility Subsystem (CAA database)
AI Active Ingredient
AIRS Aerometric Information Retrieval System (CAA database)
ASA American Society of Agronomy
BIFs Boilers and Industrial Furnaces (RCRA)
BOD Biochemical Oxygen Demand
CAA Clean Air Act
CAAA Clean Air Act Amendments of 1990
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS CERCLA Information System
CFA California Fertilizer Association
CFCs Chlorofluorocarbons
CMA Chemical Manufacturers Association
CO Carbon Monoxide
COD Chemical Oxygen Demand
CSI Common Sense Initiative
CSMA Chemical Specialties Manufacturers Association
CWA Clean Water Act
DAP Diammonium Phosphate
DOT Department of Transportation
D&B Dun and Bradstreet Marketing Index
EPA United States Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
FFDCA Federal Food, Drug, and Cosmetic Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FINDS Facility Indexing System
FIRT Fertilizer Industry Round Table
FQPA Food Quality Protection Act
HAPs Hazardous Air Pollutants (CAA)
HSDB Hazardous Substances Data Bank
IDEA Integrated Data for Enforcement Analysis
IFDC International Fertilizer Development Center
LDR Land Disposal Restrictions (RCRA)
LEPCs Local Emergency Planning Committees
MACT Maximum Achievable Control Technology (CAA)
MAP Monoammonium Phosphate
MCLGs Maximum Contaminant Level Goals
MCLs Maximum Contaminant Levels
MEA Monoethanolamine
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MEK Methyl Ethyl Ketone
MSDSs Material Safety Data Sheets
NACD National Association of Chemical Distributors
NASD A National Association of State Departments of Agriculture
NASHA North American Horticultural Supply Association
NCDB National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NEC Not Elsewhere Classified
NEIC National Enforcement Investigation Center
NESHAP National Emission Standards for Hazardous Air Pollutants
NO2 Nitrogen Dioxide
NOV Notice of Violation
NOX Nitrogen Oxide
NPCA National Pest Control Association
NPDES National Pollution Discharge Elimination System (CWA)
NPK Nitrogen-Phosphorous-Potassium
NPL National Priorities.List
NRC National Response Center
'NRDC National Resources Defense Council
NSP Normal Superphosphate
NSPS New Source Performance Standards (CAA)
OECA Office of Enforcement and Compliance Assurance
OMB Office of Management and Budget
OPA Oil Pollution Act
OPPTS Office of Prevention, Pesticides, and Toxic Substances
OSHA Occupational Safety and Health Administration
OSW Office of Solid Waste
OSWER Office of Solid Waste and Emergency Response
OW Office of Water
P2 Pollution Prevention
PCS Permit Compliance System (CWA Database)
PRP Potentially Responsible Party
POTW Publicly Owned Treatments Works
PPI Potash and Phosphate Institute
RCRA Resource Conservation.and Recovery Act
RCRIS RCRA Information System
SARA Superfund Amendments and Reauthorization Act
SDWA Safe Drinking Water Act
SEPs Supplementary Environmental Projects
SERCs State Emergency Response Commissions
SFIREG State FIFRA- Issues Research and Evaluation Group
SIC Standard Industrial Classification
SO2 Sulfur Dioxide
SOX Sulfur Oxides
TOC Total Organic Carbon
TFI The Fertilizer Institute
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TRI Toxic Release Inventory
TRIS Toxic Release Inventory System
TCRIS Toxic Chemical Release Inventory System
TSCA Toxic Substances Control Act
TSP Triple Superphosphate
TSS Total Suspended Solids
TVA Tennessee Valley Authority
UIC Underground Injection Control (SDWA)
UPFDA United Products Formulators and Distributors Association
USDA United States Department of Agriculture
UST Underground Storage Tanks (RCRA)
VOCs Volatile Organic Compounds
WCPA Western Crop Protection Association
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L INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
LA. Summary of the Sector Notebook Project
Integrated environmental policies based upon comprehensive analysis of air,
water and land pollution are a logical supplement to traditional single-media
approaches to environmental protection. Environmental regulatory agencies
are beginning to embrace comprehensive, multi-statute solutions to facility
permitting, enforcement and compliance assurance, education/outreach,
research, and regulatory development issues. The central concepts driving
the new policy direction are that pollutant releases to each environmental
medium (air, water and land) affect each other, and that environmental
strategies must actively identify and address these inter-relationships by
designing policies for the "whole" facility. One way to achieve a whole
facility focus is to- design environmental policies for similar industrial
facilities. By doing so, environmental concerns that are common to the
manufacturing of similar products can be addressed in a comprehensive
manner. Recognition of the need to develop the industrial "sector-based"
approach within the EPA Office of Compliance led to the creation of this
document.
The Sector Notebook Project was originally initiated by the Office of
Compliance within the Office of Enforcement and Compliance Assurance
(OECA) to provide its staff and managers with summary information for
eighteen specific industrial sectors. As other EPA offices, states, the
regulated community, environmental groups, and the public became
interested in this project, the scope of the original project was expanded to
its current form. The ability to design comprehensive, common sense
environmental protection measures for specific industries is dependent on
knowledge of several inter-related topics. For the purposes of this project,
the key elements chosen for inclusion are: general industry information
(economic and geographic); a description of industrial processes; pollution
outputs; pollution prevention opportunities; federal statutory and regulatory
framework; compliance history; and a description of partnerships that have
been formed between regulatory agencies, the regulated community and the
public. -
For any given industry, each topic listed above could alone be the subject of
a lengthy volume. However, in order to produce a manageable document,
this proj ect focuses on providing summary information for each topic. This
format provides the reader with a synopsis of each issue, and references
where more in-depth information is available. Text within each profile was
researched from a variety of sources, and was usually condensed from more
detailed sources pertaining to specific topics. This approach allows for a
wide coverage of activities that can be further explored based upon the
citations and references listed at the end of this profile. As a check on the
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information included, each notebook went through an external review
process. The Office of Compliance appreciates the efforts of all those that
participated in this process who enabled us to develop more complete,
accurate and up-to-date summaries. Many of those who reviewed this
notebook are listed as contacts in Section IX and may be sources of
additional information. The individuals and groups on this list do not
necessarily concur with all statements within this notebook.
I.B. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and update the
notebooks and will make these updates available both in hard copy and
electronically. If you have any comments on the existing notebook, or if you
would like to provide additional information, please send a hard copy and
computer disk to the EPA Office of Compliance, Sector Notebook Project
(2223-A), 1200 Pennsylvania Avenue, NW, Washington, DC 20460.
Comments can also be uploaded to the Enviro$en$e World Wide Web for
general access to all users of the system. Follow instructions in Appendix
A for accessing this system. Once you have logged in, procedures for
uploading text are available from the on-line Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
The scope of the industry sector described in this notebook approximates
the national occurrence of facility types within the sector. In many
instances, industries within specific geographic regions or states may have
unique characteristics that are not fully captured in these profiles. The
Office of Compliance encourages state and local environmental agencies and
other groups to supplement or repackage the information included in this
notebook to include more specific industrial and regulatory information that
may be available. Additionally, interested states may want to supplement
the "Summary of Applicable Federal Statutes and Regulations" section with
' state and local requirements. Compliance or technical assistance providers
may also want to develop the "Pollution Prevention" section in more detail.
Please contact the appropriate specialist listed on the opening page of this
notebook if your office is interested in assisting us in the further
development of the information or policies addressed within this volume.
If you are interested in assisting in the development of new notebooks for
sectors not covered in the original eighteen, please contact the Office of
Compliance at 202-564-2310.
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Agricultural Chemical Industry ___ Introduction and Scope
II. INTRODUCTION TO THE AGRICULTURAL CHEMICAL INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and economic condition of the
fertilizer, pesticide, and agricultural chemical industry. Facilities described
within this document are described in terms of their Standard Industrial
Classification (SIC) codes whenever possible.
II.A. Introduction, Background, and Scope of the Notebook
The scope of this Sector Notebook covers the manufacturing and production
of fertilizers, the formulation of pesticide chemicals (both agricultural and
non-agricultural) manufactured at separate facilities, and the production of
other miscellaneous agricultural chemicals. It does not include the use, sale,
distribution, or storage of such chemicals.
The Fertilizer, Pesticide, and Agricultural Chemical Industry is classified by
the Office of Management and Budget (OMB) under Standard Industrial
Classification (SIC) Industry Group Number 287. This classification
corresponds to SIC codes which were established by the OMB to track the
flow of goods and services within the economy. Industry Group Number 287
includes SIC codes:
2873— Nitrogenous Fertilizers
2874- Phosphatic Fertilizers
2875- Fertilizers, Mixing Only
2879— Pesticides and Agricultural Chemicals, Not Elsewhere
Classified (n.e.c)
This notebook covers both fertilizer manufacturing and formulating
operations including ammonia synthesis, nitric and phosphoric acid
production, and the mixing, preparing, and packaging of nitrogenous and
phosphatic fertilizers. Establishments engaged in manufacturing fertilizer
materials or mixing fertilizers produced at the same establishment are
classified under SIC codes 2873 and 2874. Mixing of fertilizer materials,
such as compost, potting soil, and fertilizers made in plants not
manufacturing fertilizer materials, is classified under SIC code 2875. This
notebook does not include the mining or grinding of phosphate rock, which
is classified under SIC code 1475, and it also does not include the use or
application of fertilizers.
SIC code 2879, pesticides and agricultural chemicals not elsewhere classified
(n.e.c.), hereafter referred to as pesticides and miscellaneous agricultural
chemicals, covers only the formulating, preparing, and packaging of ready-to-
use agricultural and household pest control chemicals. This industry code
also includes establishments primarily engaged in the manufacturing or
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Agricultural Chemical Industry
Introduction and Scope
formulating of agricultural chemicals, not elsewhere classified, such as minor
or trace elements and soil conditioners. This notebook does not discuss the
, use or application of pesticide products. Establishments primarily engaged
in the manufacturing of basic or technical agricultural pesticides are classified
in Industry Group 281 if the chemicals produced are inorganic or Industry
Group 286 if the chemicals produced are organic. This notebook also does
not cover the agricultural supply sector, SIC 5191, which is engaged in the
wholesale and distribution of various agricultural supplies including
fertilizers and pesticides. Also, there is little discussion of the potassium
fertilizer industry as potash is classified under SIC 2819, Inorganic
Chemicals n.e.c.
Federal government agencies, including United States EPA, are beginning to
implement an industrial classification system developed by OMB to replace
the SIC code system. The new system, which is based on similar production
processes, is called the North American Industrial Classification System
(NAICS). In the NAIC system, the manufacturing of nitrogenous fertilizers
(SIC 2873) is classified as NAIC 325311, phosphatic fertilizers (SIC 2874)
as NAIC 325312, and fertilizer mixing only (SIC 2875) as NAIC 325314.
Pesticide formulating and agricultural chemicals n.e.c. (SIC 2879) is
classified under NAIC 32532. Because EPA databases, and other databases
used in this document, are still using the SIC system, the industry sectors
described in this Sector Notebook are described in terms of their SIC codes.
II.B. Characterization of the Fertilizer, Pesticide, and Agricultural Chemical Industry
As the world population increases, crop lands are unable to meet the growing
demand for food without employing some method of crop enhancement.
There are five common practices used to meet the growing demand:
• increasing tilled acreage
• improving plant strains
• introducing or expanding irrigation
• controlling pest by chemical or biological methods
• initiating or increasing fertilizer usage
Increased utilization of the last two methods has created a large agrichemical
industry which produces a wide variety of products designed to increase crop
production and protect crops from disease and pests (Kent, 1992). Together,
the production of fertilizers and the formulation of pesticides was a $18.8
billion industry in 1992, employing over 40,000 people (USDOC, 1995).
Plants require 18 elements to grow, the most important being oxygen, carbon,
hydrogen, nitrogen, phosphorous, and potassium. Oxygen, carbon, and
hydrogen are obtained from the atmosphere and water, while nitrogen,
phosphorous, and potassium are naturally obtained from soil. However,
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Introduction and Scope
under current high yield production methods, soils are stripped of the
essential nutrients, requiring the addition of fertilizers (primarily consisting
of nitrogen, phosphorous, and potassium) to resupply the land. The
additional 12 essential nutrients are generally maintained in soil at sufficient
levels for plant growth, but they may be added to some fertilizers (Kent
1992).
Even before the addition of nutrients to farm lands, farmers were forced to
protect their crops against pests with chemicals. References to pesticide
usage date back to 1000 B.C. Pests are continuously adapting to pesticide
chemicals requiring new pesticides and the usage of multiple chemical
agents. The industry is rapidly changing due to biological adaptation of pests,
laboratory discoveries, and government regulation (Kent, 1992). The
pesticide industry is faced with the need for new formulations and the
abundance of possible combinations, but restricted by cost factors and a
sometimes lengthy registration process.
Pesticides are.applied on about three-quarters of United States farms and
households. Farmers' expenditures on pesticides were equal to 4.6 percent
of total farm production expenditures in 1995, up from 3.9 percent in 1993.
About one billion pounds of active ingredient of conventional pesticides are
used annually in the United States; this usage involves about 21,000 pesticide
products (including non-agricultural products) and 875 active ingredients
registered under the Federal Pesticide Law, according to the 1994 and 1995
Market Estimates for Pesticides Industry Sales and Usage (Aspelin, 1997).
II.B.l. Product Characterization
This 'notebook covers all aspects of fertilizer production and pesticide
formulating and packaging. However, because the industrial processes,
pollutant outputs, economics, size, and geographic distribution of the two
industries are different, they are dealt with separately throughout the
notebook.
Figure 1 compares the number of manufacturing facilities and value of
shipments for each of the major sectors within the Fertilizer, Pesticide, and
Agricultural Chemical Industry, as reported by the United States Bureau of
Census. The figure shows that the fertilizer mixing industry has the largest
number of facilities but the smallest value of shipments. This reflects that,
compared to other sub-sectors within the Fertilizer, Pesticide and Agricultural
Chemical Industry, these facilities produce a relatively small volume of
product and sell a relatively low value product. Phosphatic fertilizer
producers,,on the other hand, comprise the smallest number of facilities but
have a relatively large share of the industry's value of shipments, reflecting
that individual facilities produce a relatively large volume of product.
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Figure 1: Number of Facilities and Value of Shipments of the Fertilizer,
Pesticide, and Agricultural Chemical Manufacturing Industry
(number of manufacturing facilities) (millions of dollars)
75 $4,049.4 ^^^^
$3,588.4
401
152
$1,781.5
263
$8,234.8
Nitrogenous Fertilizers
Phosphatic Fertilizers
Fertilizers, Mixing only
Pesticides and Ag. Chem. N.E.C.
Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, United States
Department of Commerce, Bureau of the Census, May 1995.
* United States EPA has identified over 8,000 establishments that could fall -within this SIC code
as it is defined by the OMB. See discussion in text below.
The Census of Manufacturers reports 263 establishments that can be defined
as producing pesticides and miscellaneous agricultural chemicals. These
establishments reportedly account for almost half of the value of shipments
for the sector. There are over 8,000 establishments identified by the United
States EPA that manufacture, formulate and package pesticides and other
agricultural chemicals and that could fall within OMB's SIC code definition
for this sector. Many of these are small establishments and establishments
that have a primary line of business other than producing pesticides and other
miscellaneous agricultural chemicals. The Census only counts those facilities
which report an SIC code as their primary line of business, thus the number
of facilities shown above is not inclusive of all facilities involved in
agricultural chemical production. Under the "Pesticides and Miscellaneous
Agricultural Chemicals" heading later in this section, other pesticide
producing establishment counts are presented based on EPA estimates and
reporting under section 7 of the Federal Insecticide, Fungicide, and
Rodenticide Act.
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Nitrogenous Fertilizers
The nitrogenous fertilizer industry includes the production of synthetic
ammonia, nitric acid, ammonium nitrate, and urea. Synthetic ammonia and
nitric acid, however, are used primarily as intermediates in the production of
ammonium nitrate and urea fertilizers. Table 1 lists specific products
classified as nitrogenous fertilizers by OMB.
Table 1: Nitrogenous Fertilizer Products
(SIC 2873)
Ammonia liquor
Ammonium nitrate
Ammonium sulfate
Anhydrous ammonia
Aqua ammonia
Fertilizers, mixed, produced in nitrogenous fertilizer plants
Fertilizers, natural
Nitric acid
Nitrogen fertilizer solutions
Plant foods, mixed in nitrogenous fertilizer plants
Urea
Source: Standard Industrial Classification Manual, Office of
Management and Budget, 198 7.
Synthetic Ammonia
Synthetic ammonia refers to ammonia that has been synthesized from natural
gas. In this process, natural gas molecules are reduced to carbon and
hydrogen. The hydrogen is then purified and reacted with nitrogen to
produce ammonia. Approximately 75 percent of the synthetic ammonia
produced in the United States is used as fertilizer, either directly as ammonia
or indirectly after fertilizer synthesis into urea, ammonium nitrate, and
monoammonium or diammonium phosphates. One-third of the fertilizer
nitrogen is applied directly to the land as anhydrous ammonia. The remaining
25 percent of ammonia produced in the United States is used as raw material
in the manufacture of polymeric resins, explosives, nitric acid, and other
products (USEPA, 1993a).
Nitric Acid
Nitric acid is formed by concentration, absorption, and oxidation of
anhydrous ammonia. About 70 percent of the nitric acid produced is
consumed as an intermediate in the manufacture of ammonium nitrate
(NH4NO3), which is primarily used in fertilizers. Another 5 to 10 percent of
the nitric acid produced is used in adipic acid manufacturing, an intermediate
in nylon production. Explosive manufacturing utilizes nitric acid for organic
nitrations to produce nitrobenzene, dinitrotoluenes, and other chemical
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intermediates. Other end uses of nitric acid are gold and silver separation,
military munitions, steel and brass pickling, photoengraving, and acidulation
of phosphate rock (USEPA, 1993a).
Ammonium Nitrate
Ammoniurn nitrate is produced by neutralizing nitric acid with ammonia.
Approximately 15 to 20 percent of ammonium nitrate is used for explosives
and the balance for fertilizer. Ammonium nitrate is marketed in several
forms, depending upon its use. Liquid ammonium nitrate may be sold as a
fertilizer, generally in combination with urea. Liquid ammonium nitrate may
also be concentrated to form an ammonium nitrate "melt" for use in solids
formation processes. Solid ammonium nitrate may be produced in the form
of prills, grains, granules or crystals. Prills, round or needle-shaped
aggregates, can be produced in either high or low density form, depending on
the concentration of the melt. High density prills, granules and crystals are
used as fertilizer, grains are used solely in explosives, and low density prills
can be used as either fertilizer or explosives (USEPA, 1993a).
Urea
Urea, also known as carbamide or carbonyl diamide, is produced by reacting
ammonia with carbon dioxide. Eighty-five percent of urea solution produced
is used in fertilizer mixtures, with three percent going to animal feed
supplements and 12 percent is used for plastics and other uses. Urea is
marketed as a solution or in solid form. Most solids are produced as prills or
granules for use as fertilizer or protein supplement in animal feed, and in,
plastics manufacturing (USEPA, 1993a).
Ammonium sulfate
It is not economically feasible to produce ammonium sulfate for use as a
fertilizer. However, ammonium sulfate is formed as a by-product of other
process such as acid scrubbing of coke oven gas, synthetic fiber production,
and the ammoniation of process sulfuric acid (Hoffmeister, 1993). Therefore,
the production of ammonium sulfate is not described in this notebook.
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Figure 2: Product Distribution for SIC 2873, Nitrogenous Fertilizers
1996 Production
(in thousands of tons)
16,814
3,060
Ammonia
Urea
2,605
5,551
I I Ammonium nitrate
• Ammonium sulfate
Source: Fertilizer Institute data as reported in Chemical and Engineering News, June 23, 1998. Figures
are based on Fertilizer Institute surveys and may not represent the entire industry.
Phosphatic Fertilizers
The phosphatic fertilizer industry can be divided into three major segments:
phosphoric acid, granular ammonium phosphate, and normal and triple
superphosphate. Table 2 lists these, and a few additional, less common
products classified as phosphatic fertilizers by OMB.
Table 2: Phosphatic Fertilizer
Products (SIC 2874)
Ammonium phosphates
Calcium meta-phosphates
Defluorinated phosphates
Diammonium phosphates
Fertilizers, mixed, produced in phosphatic fertilizer
plants
Phosphoric acid
Plant foods, mixed in phosphatic fertilizer plants
Superphosphates, amtnoniated and not ammoniated
Source: Standard Industrial Classification Manual, Office of
Management and Budget, 1987.
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Phosphoric Acid
Phosphoric acid (H3PO4) can be manufactured using either a wet or a thermal
process to react phosphate rock with sulfuric acid. Approximately 96 percent
of the phosphoric acid produced in the United States is produced using the
wet process. Wet process phosphoric acid has a phosphorous concentration
typically ranging from 26-30% as phosphorous pentoxide (P2O5) and is used
in the production of ammonium phosphates and triple superphosphates.
Thermal process phosphoric acid is commonly used in the manufacture of
high grade chemicals requiring a much higher purity.
Ammonium Phosphates
Ammonium phosphate (NH4H2PO4) is produced by reacting phosphoric acid
with anhydrous ammonia. Both solid and liquid ammonium phosphatic
fertilizers are produced in the United States The most common ammonium
phosphatic fertilizer grades are monoammonium phosphate (MAP) and
diammonium phosphate (DAP). DAP has become one of the most commonly
used fertilizers because it provides a large quantity of plant food, is
compatible with most mix fertilizer ingredients, and is nonexplosive. It may
be directly applied or used in irrigation systems as it is completely soluble in
water. DAP is also preferred over MAP because it is capable of fixing twice
as much ammonia per phosphorous pentoxide in solid form (Nielson, 1987.)
MAP contains a higher concentration of phosphorous pentoxide than DAP.
It is favored for use with alkaline soils and may be applied either directly or
in a dry blend.
Normal Superphosphates
Like phosphoric acid, normal, or "ordinary," superphosphate fertilizers are
produced by reacting phosphate rock with sulfuric acid. However, normal
superphosphate (NSP) retains calcium sulfate which forms by the reaction
between phosphate rock and sulfuric acid. For this reason NSP retains its
importance wherever sulphur deficiency limits crop yields (UNEP, 1996).
NSP refers to fertilizer material containing 15 to 21 percent phosphorous as
phosphorous pentoxide (P2O5). As defined by the Census Bureau, NSP
contains not more than 22 percent of available P2O5 (USEPA, 1993a).
Production of NSP has given way to the higher-yielding triple
superphosphates and ammonium phosphates. In 1990, production of NSP
accounted for only one percent by weight of the phosphorous fertilizer
industry. Because of its low P2O5 concentration, shipping can be
prohibitively expensive due to the large volumes required. NSP is favored
in low cost Nitrogen-Phosphorous-Potassium (NPK) mixes because it is a
less expensive form of phosphorous, however, it is unacceptable for higher-
grade mixes (Kent, 1992).
Triple Superphosphates
Triple superphosphates (TSP) are produced by reacting ground phosphate
rock with phosphoric acid. Triple superphosphate is also known as double,
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treble, or concentrated superphosphate. The phosphorus content of triple
superphosphates is over 40 percent, measured as phosphorus pentoxide
(P2O5), which is its main advantage over other phosphatic fertilizers (USEPA,
1993a). TSP began to be produced in large quantities when wet process
phosphoric acid production became available commercially. It is commonly
produced along with phosphoric acid near phosphate rock supplies. TSP may
be applied directly or as a bulk blend (Kent, 1992).
Figure 3; Product Distribution for SIC 2874, Phosphorous Fertilizers
1996 Production
(in thousands of tons)
12,511
1,701
15,575
Phosphoric acid
Diammonium phosphate
3,332
Concentrated superphosphate
Monoammonium phosphate
Source: Chemical and Engineer ing News, June 23, 1998. Figures are based on Fertilizer
Institute surveys and may not represent the entire industry.
Fertilizers, Mixing Only
A significant part of the fertilizer industry only purchases fertilizer materials
in bulk from fertilizer manufacturing facilities and mixes them to sell as a
fertilizer formulation.
Phosphorous is the single nutrient most likely to be applied in a fertilizer
mixture, as seen in Table 3.
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Table 3: 1990 Direct vs Mixed Application of
Primary Fertilizer Nutrients
Nutrient
Nitrogen
Phosphorous
Potassium
TOTAL
Method, % applied
Direct
80
8
65
61
Mixtures
20
92
35
39
Source: Hoffmeister, G., "Fertilizers, " Kirk-Othmer
Encyclopedia of Chemical Technology, V. 10, 1993.
Although the Bureau of the Census only counts 401 facilities reporting the
SIC code for fertilizer mixing (2875) in 1992, other sources estimated the
true number of fertilizer mixing facilities to be closer to five or six thousand
in 1984 (Adrilenas and Vroomen, 1990). About half of applied fertilizers are
bulk blends. Fertilizer mixing facilities generally serve a small area such as
farms within a ten to fifty mile radius. The processes involved are simple and
relatively little value is added to the raw materials purchased by mixing
facilities. Nevertheless, there are many of these facilities and volume of
production results in a $ 1.8 billion industry (value of annual shipments). The
industrial process is simple and resembles that of the pesticide formulating
sector. A brief discussion of fertilizer mixing processes is included in this
notebook.
Pesticides and Miscellaneous Agricultural Chemicals
The pesticides and agricultural chemicals n.e.c. (referred to here as pesticides
and miscellaneous agricultural chemicals) industry group (SIC 2879)
formulates and prepares ready to use agricultural and household pesticides
and other agricultural chemicals. The manufacture of pesticide active
ingredients is classified under either Industry Group 281 for inorganic
chemicals or 286 for organics which are not covered by this notebook. (See
Profile of the Inorganic Chemicals Industry and Profile of the Organic
Chemicals Industry Sector Notebooks.) In the United States, over 850
different pesticide formulations and preparations are produced. In 1995, 31
new active ingredients were registered in the United States (Aspelin, 1997).
Most of these pesticides can be classified as either insecticides, herbicides,
or fungicides, although many other minor classifications exist. Also included
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in this category are blends of fertilizers and pesticides produced at pesticide
formulating and mixing facilities. Table 4 lists the pesticides and other
products included in SIC 2879.
Table 4: SIC 2879 Pesticides and Miscellaneous Agricultural
Chemicals, List of Products
Agricultural disinfectants
Agricultural pesticides
Arsenates and arsenites
Bordeaux mixture
Cattle dips and sheep dips
DDT
Defoliants
Fly sprays
Fungicides
Growth regulants
Herbicides
Insecticides, agricultural and
household
Lime-sulfur, dry and solution
Lindane, formulated
Moth repellants
Nicotine and salts
Paris green
Pesticides, household
Phytoactin
Plant hormones
Poison, household
Pyrethrin
Rodenticides
Rotenone
Soil conditioners
Sulfur dust
Thiocyanates
Trace elements
(agrichemical)
Xanthone
Source: Standard Industrial Classification Manual, Office of Management and Budget, 1987.
In 1995, 77 percent (by volume) of all pesticides were used for agriculture,
12 percent for industrial, commercial, or governmental lands or facilities, and
11 percent for homes and gardens (Aspelin, 1997). Non-agricultural
pesticides and miscellaneous agricultural chemicals are included in the data
presented for sales, production, waste management, and enforcement and
compliance. However, since they represent a relatively small part of the
industry and cover a wide range of chemicals and production processes, these
products are not covered in the Industrial Processes and Pollutant Outputs
sections of this document.
Herbicides
Herbicides (in both value and quantity) are the largest class of pesticides used
in the United States, as well as in the world. This class of pesticides, which
accounts for approximately fifty percent of the value of aggregate world
pesticide usage, is used to destroy or control a wide variety of weeds and
other unwanted plants. Because of its demonstrated farm labor savings,
nearly all the agricultural land in the United States is currently being treated
with some type of herbicide. In recent years, approximately fifty percent of
total United States pesticide consumption (by value) was herbicides (USITC,
1994).
Insecticides
Insecticides are the second largest pesticide category (by value) used in the
United States and in the world. In the early 1990s, insecticides accounted for
approximately twenty-nine percent of the total value of United States
pesticide consumption. Historically, the category of synthetic organic
insecticides has been divided into one of four major chemical groups:
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• organochlorines (e.g., DDT and chlordane)
• organophosphates (e.g., parathion and diazinon)
• carbamates (e.g., carbaryl)
1 • pyrethroids (e.g., natural and synthetic)
Several compounds, discovered during the 1950s, found widespread use in
agriculture because of their high toxicity to a variety of insects. However, the
qualities that made these chemicals so desirable also led to their eventual
removal from the market, as these products also proved harmful to humans
and to the environment. Spurred in part by increased environmental concern,
researchers developed a new series of less toxic synthetic compounds called
pyrethroids. These compounds are based on the natural pyrethroids, which
are found in such plants as the chrysanthemum (USITC, 1994).
Fungicides
In recent years, fungicides accounted for approximately ten percent of the
value of total United States pesticide consumption. Fungicides are used
today primarily to protect agricultural crops and seeds from various fungi;
farmers previously used inorganic products, such as elemental sulfur and
copper sulfate. Initially, synthetic products were commercially unsuccessful,
because of their high manufacturing costs. By the 1940s, however, newer,
less expensive products became commercially successful. Today, fungicides
are manufactured from a variety of chemical classes. Commercially, the most
important fungicides are halogenated compounds, the carbamates and
dithiocarbamates, and organophosphates (USITC, 1994).
Other Pesticides
Although small in total quantity consumed, a number of other classes of
pesticide products are on the market. Some of these pesticides are not
covered by this Notebook.
• Biological pesticides, also known as biopesticides, include true
biological agents, living or reproduced biological entities such as viruses
or bacteria, and naturally occurring biochemicals such as plant growth
regulators, hormones, and insect sexual attractants (pheromones) that
function by modes of action other than innate toxicity. At the end of
1998, there were approximately 175 registered biopesticide active
ingredients and 700 products. Generally, biological pesticides pose little
or no risk to human health or the environment. Accordingly EPA
generally requires much less data to register a biopesticide than to register
a conventional pesticide (USEPA, 1999). To further facilitate the
•registration of biopesticides, in 1994, EPA established the Biopesticides
and Pollution Prevention Division in the Office of Pesticide Programs.
• Plant growth regulators have been developed by many companies to
improve crop production. Plant growth regulators are produced for a
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variety of purposes, including loosening ripened fruits for faster harvest;
controlling the size and firmness of fruits; and regulating the size of a
plant to increase branching. These products account for a small portion
of world and United States usage. Future development will probably be
directed toward selected crops for which the application of these specialty
products is found to be the most cost effective (USITC, 1994).
• Sex attractants may be used to attract insects to traps or to confuse
specific male insects, making it difficult to locate females for mating.
Commercially available sexual attractants are synthetically produced
compounds. Insect growth regulators, such as juvenile growth hormones,
are synthetic compounds similar to the natural chemicals that regulate
insect growth.
• Genetically modified plants are plants developed through the use of
biotechnology. There are three types of plants that are relevant to pest
control: herbicide-tolerant plants (which can tolerate certain types of
herbicides), insect-resistant plants (which can withstand attacks by certain
insects), and virus- and other pest-resistant plants (which are immune to
some types of plant viruses and other plant pests). As of September
1994, several genetically modified plants had been commercialized and
had elicited optimism that genetically modified plants would become an
important new approach to controlling pests (USDA, 1995).
The environmental benefits of reduced use of chemical pesticides are also
significant. Environmental side effects of traditional pesticides include the
cost of providing alternative sources of drinking water, increased treatment
costs for public and private water systems, lost boating and swimming
opportunities, worker safety concerns, exposure to nearby residents, increased
exposures for farm children, possible loss of biodiversity, pressure on
threatened and endangered species, and damage to recreational and fishery
resources (USDA, 1995).
Pesticide Formulations
Pesticide formulations may exist in any of the three following physical states:
liquid, dry, and pressurized gas. The liquid formulation may be applied
directly in liquid form or propelled as an aerosol. Some common dry-based
formulations are dusts, wettable powders, granules, treated seed, bait pellets,
encapsulated, and cubes. Pressurized gas formulations are used primarily for
soil fumigation (USEPA, 1996). Gaseous pesticides can be subjected to high
pressures which often convert the formulation to a liquid which can be stored,
transported and applied from gas cylinders.
Repackaging of pesticide formulations is common when materials are to be
transferred from bulk storage to a smaller scale of packaging for use by a
consumer. Products are typically repackaged in smaller containers and
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consumer-specific labeling is added (USEPA, 1996).
In 1995, roughly 79 percent of all pesticides were used on agricultural
cropland. The remainder were used in private homes and gardens and on
commercial and industrial property (Aspelin, 1997). Therefore, although non-
agricultural pesticides are included in SIC code 2879 and thus the notebook,
the specific packaging or formulating requirements of those products are not
included. However, the sales, production, pollutant releases, and
enforcement and compliance data reflect non-agricultural pesticides as well
as agricultural pesticides.
The majority of pesticides were used on only a few major crops: cotton, corn,
soybeans, and apples. The major pesticide chemicals used in United States
agricultural crop production are atrazine, metolachlor, metam sodium, methyl
bromide1, and dichloropropene (Aspelin, 1997).
Figure 4: Product Distribution for SIC 2879, Pesticides and Miscellaneous
Agricultural Chemicals ^^^^
1996 Production
(in millions of pounds)
568
185
Herbicides
Fungicides
Insecticides
Plant Growth Regulators
Source: American Crop Protection Association, asreportedin Chemical and Engineering News, June23,1998.
1 Production and importation of methyl bromide is currently being phased out. It will be reduced from 1991 levels
and will be completely phased out in 2005.
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Establishment Reporting Under FIFRA Section 7
Information reported under section 7 of the Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) is another source of facility level data for the
pesticides industry. All establishments that produce pesticides in the United
States or that import pesticides into the United States are required to register
and report their production volume to the EPA. These data differ from the
Census of Manufacturers data presented above for the agricultural chemical
industry as a whole. The Census of Manufacturers data only covers facilities
that are manufacturing these products, while the FIFRA data system more
broadly includes establishments that "produce" these products. The term,
"produce" has been defined under FIFRA and 40 CFR Part 167 to mean "to
manufacture, prepare, propagate, compound, or process any pesticide,
including any pesticide produced pursuant to section 5 of FIFRA, any active
ingredient, or device, or to package, repackage, label, relabel, or otherwise
change the container of any pesticide or device." Repackaging or otherwise
changing the container of any pesticide or device in bulk amounts constitutes
pesticide production. Under FIFRA section 7, products are reported under
one of four product types:
1) Technical material or active ingredient
2) End-use blend, formulation, or concentrate
3) Repackaged or relabeled product
4) Device
The total number of establishments, domestic and foreign, that reported to
EPA under FIFRA section 7 are presented in Table 5. Although there are
approximately twelve to thirteen thousand Active Registered
Pesticide-Producing Establishments, table 5 below only lists establishments
that reported actual production for the calender year 1996. The
establishments that reported either zero production or who were non-reporters
for calender year 1996 are not Included in the establishment number totals in
the table. The significant difference between the pesticide producing
establishment counts as reported under section 7 (8,612) and the pesticide and
agricultural chemical manufacturers n.e.c. reported by the Census (263) can
be attributed to the section 7 broad inclusion of producers vs. the relatively
narrow, Census inclusion of manufacturers. In addition, the Census of
Manufacturers uses SIC code definitions which lump many pesticide active
ingredient manufacturers into SIC codes that represent organic or inorganic
chemicals. Establishments classified under the first product type, as well as
some of the second, may include facilities classified under the chemical
manufacturing SIC codes 286 or 281. Also, the Census only counts a facility
in an SIC code if they report a product in that SIC code as their primary line
of business. Therefore, facilities producing a variety of products might not
be classified under all applicable SIC codes. For example, a facility which
produces many different types of fertilizers as well as some pesticides might
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only be counted under the fertilizer SIC codes by the Census Bureau to avoid
double counting of facilities.
Table 5: Establishment Counts Based on Product
Type*
Type
1
2
3
4
Product
Technical Material,
Active Ingredient
End-Use Blend,
Formulation,
Concentrate
Repackaged or
Relabeled Goods
Devices
Total
Total
555
2,590
5,267
200
8,612
Domestic
410
2,454
5,243
166
8,273
Foreign
145
136
24
34
339
Source: U.S.EPA, Enforcement, Planning, Targeting & Data
Division,, FIFRA, section 7 Data System, United States EPA. 1996.
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II.B.2. Industry Size and Geographic Distribution
Table 6 lists the facility size distribution within the nitrogenous fertilizer,
phosphatic fertilizer, fertilizer mixing, and pesticide and agrichemical
formulating industries. For each industry code, the majority of facilities
employ less than 50 people.
Table 6: Facility Size Distribution for the Fertilizer, Pesticide, and Agricultural Chemical
Manufacturing Industry
Employees
per Facility
1-9 •> •
-1Q.-49" /
50-249
250-499
500-2499
Total
FERTILIZERS
Nitrogenous
Fertilizers
(SIC 2873)
Number
of
Facilities
60.
-47' *--,
43
1
1
152
Percentage
of
Facilities
39% •
31% - -%«
28%
1%
1%
100%
Phosphatic
Fertilizers (SIC
2874)
Number
of
Facilities
27~ ~
T^-.V *
15
6
5
75
Percentage
of
Facilities
"36%^
-"*'«*
29%
20%
8%
7%
100%
Fertilizers, Mixing
only
(SIC 2875)
Number
of
Facilities
205 v
'•166' "„
30
0
0
401
Percentage
of
Facilities
51% *-
41% '•
8%
0%
0%
100%
PESTICIDES
Pesticides and
other
Agrichemicals
(SIC 2879)*
Number
of
Facilities
108. .*
-95'', ''
45
7
8
263*
Percentage
of ''-
Facilities
,41%
36%.
17%
3%
3%
100%
Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, US Department of Commerce, Bureau of the Census
May 1995. , '
Note: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location, and employment
figures since 1992 are not reflected in these data.
United States EPA -has identified over 8, 600 registered pesticide producing establishments. The SIC code as it is defined by the
OMB only includes 263 of those establishments.
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Figure 5 shows the United States distribution of fertilizer manufacturing and
mixing facilities. The geographic distribution of nitrogenous and phosphatic
fertilizer manufacturers is determined by natural resources and demand.
Seventy percent of synthetic ammonia plants in the United States are
concentrated in Louisiana, Texas, Oklahoma, Iowa, and Nebraska due to
abundant natural gas supplies. The majority of nitric acid plants are located
in agricultural regions such as the Midwest, South Central, and Gulf States
in order to accommodate the high volume of fertilizer usage. Florida has the
largest phosphate rock supply in the United States, thus phosphoric acid
manufacturing is concentrated primarily in Florida and spreads into the
Southeast.
FigureS: Geographic Distribution of the Fertilizer Industry (SIC 2873,2874,2875)
Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, United States
Department of Commerce, Bureau of the Census, May 1995.
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Introduction and Scope
Table 7 further divides the geographic distribution of fertilizer manufacturing
and mixing facilities. The top states in which the nitrogenous fertilizer,
phosphatic fertilizer, and fertilizer mixing industries are concentrated are
given along with their respective number of establishments. Florida's supply
of phosphate rock causes a concentration of phosphatic and mixed fertilizer
facilities, while nitrogenous fertilizer plants are often located near sources of
raw materials.
Table 7: States with the Largest Number of Fertilizer Manufacturing Facilities
States in which
industry is
concentrated, based
on number of
establishments
% of total
Nitrogenous
Fertilizers
(SIC 2873)
Top
States
California
Texas
Louisiana
Establish-
ments
17
12
8
24%
Phosphatic
Fertilizers
(SIC 2874)
Top
States
Florida
North
Carolina
Establish-
ments
15
9
32%
Fertilizers,
Mixing only
(SIC 2875)
Top
States
Florida
Ohio
Texas
Establish-
ments
42
31
26
25%
Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, US Department of Commerce,
Bureau of the Census, May 1995.
Note: 1992 Census of Manufacturers data are the most recent available. Changes in the number of facilities, location,
and employment figures since 1992 are not reflected in these data.
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Figure 6 shows the United States distribution of pesticide formulating and
miscellaneous agrichemical formulating facilities. The distribution follows
the general distribution of the petrochemical industry (coasts and Great
Lakes) which the industry relies on for its raw materials, and the distribution
of agricultural production in the United States (Midwest and Great Plains
states).
Figure 6: Geographic Distribution of the Pesticide Formulating and Miscellaneous
Agrichemical Formulating Facilities (SIC 2879)* •
Source: 1992 Census of Manufacturers, Industry Series: Agricultural Chemicals, United States Department
of Commerce, Bureau of the Census, May 1995.
* United States EPA has identified over 8,000 establishments that could fall within this SIC code as it is
defined by the OMB.
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Table 8: Top United States Agricultural Chemical Companies
Rank
1
2
3
4
5
6
7
8
9
10
Company
IMC Global - Northbrook, IL
Zeneca Inc. - Wilmington, DE
Agrium United States Inc. - Spokane,
WA
CF Industries, Inc. - Lake Zurich, IL
PCS Nitrogen Inc. - Memphis, TN
Dowelanco (now named Dow
AgriSciences) - Indianapolis, IN
The Scotts Company - Marysville, OH
Cargill Fertilizer - Riverview, FL
ChemFirst Inc. - Jackson, MS
La Roche Industries Inc. - Atlanta, GA
1997 Sales
(millions of
dollars)
2,981
2,822
1,814
1,383
1,310
1,288
752
600
595
449
SIC Code(s) Reported
2874, 2875, 2819, 1474, 1475
2879, 2834,2899
2873
2873, 2874
2873, 2874
2879
2873, 2874, 2879, 0139, 2499,
3524
2874
2873,2865,3567,3312
2873, 5191, 2812, 2869, 3291,
3569
Source: Dun & Bradstreet's Million Dollar Directory, 1997
Note: Not all sales can be attributed to the companies agricultural chemical operations.
Dun & Bradstreet's Million Dollar Directory, compiles financial data on
United States companies including those operating within the Fertilizer,
Pesticide, and Agricultural Chemical Industry. Dun & Bradstreet ranks
United States companies, whether they are a parent company, subsidiary or
division, by sales volume within their assigned 4-digit SIC code. Readers
should note that: (1) companies are assigned a 4-digit SIC code that
resembles their principal industry most closely; and (2) sales figures include
total company sales, including subsidiaries and operations (possibly not
related to agricultural chemicals). Additional sources of company specific
financial information include Standard & Poor's Stock Report Service,
Ward's Business Directory of United States Public and Private Companies,
Moody's Manuals, and annual reports.
The Bureau of the Census publishes concentration ratios, which measure the
degree of competition hi a market. They compute the value of shipments
percentage controlled by the top 4, 8, 20, and 50 companies in a given
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industry. Within the agricultural chemical industry, the phosphatic fertilizer
industry had the highest concentration ratio for the top four companies in
1992,62 percent. The pesticide and other agricultural chemicals, nitrogenous
fertilizers, and fertilizer mixing industries' concentration ratios were 53,48,
and 19 percent respectively.
II.B.3. Economic Trends
The United States is a major producer and exporter of agricultural chemicals.
It is the largest producer of phosphatic fertilizers and pesticides and the
second largest producer of nitrogenous fertilizers in the world (USDOC,
1998).
Domestic Market Trends
The majority of important crops, such as corn and soybeans, are grown using
fertilizers and pesticides. As a result, year-to-year changes in the domestic
demand for agrichemicals reflect the level of planted acreage, which in turn
is affected by grain prices and weather conditions. Increases in planted
acreage of corn, feedgrains and other crops in recent years have resulted in
increased demand and production of agrichemicals in the United States.
Industry shipments of agricultural chemicals should show modest annual
growth through the end of the decade (USDOC, 1998).
The Federal Agricultural Improvement and Reform Act of 1996 could have
a major long-term impact on the agricultural chemical industry. This law
gives farmers greater flexibility in making planting decisions and allows them
to rely more on the marketplace as a guide for crop plantings. The bill
eliminates the annual acreage set-aside program, thus potentially boosting the
levels of crop acreage (USDOC, 1998).
Agricultural chemical production showed little change between 1995 and
1996. Total production was approximately 103 million pounds each year.
However, experts claim that due to lower dosage requirements for pesticides,
agrichemical demand is actually higher than it would appear. Pesticides saw
a six percent rise in production from 1995 to 1996. Nitrogenous fertilizer
production was up approximately seven percent, and phosphate production
increased slightly except for its major product, diammonium phosphate.
Prices for agricultural chemicals rose three percent from 1995 to 1996, while
the number of production workers fell two percent (USDOC, 1998).
International Market Trends
The United States accounts for more than 50 percent of world trade in
phosphatic fertilizers, with a two-thirds share of total trade in DAP
(diammonium phosphate), the principal phosphatic fertilizer product.
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Agricultural Chemical Industry ________ Introduction and Scope
Exports generally account for about half of total shipments for the United
States phosphatic fertilizer industry, with about half of all exports going to
China.
International markets, especially less developed nations in Asia and Latin
America, hold greater market potential for the agrichemicals industry as
population levels grow, income levels rise, and demands for better standards
of living and diets increase the need for grain production. From the current
level of about 5.8 billion, the world population is expected to increase by
about 80 million each year between 1996 and 2000. Developing nations are
becoming more sophisticated in agricultural practices, thus increasing their
usage of fertilizers and pesticides to improve production (USDOC, 1998).
The United States has been a net exporter of pesticide chemicals, and this is
expected to continue through the turn of the century. Exports of pesticides
accounted for about 25 percent of United States pesticide production in 1994,
according to The American Crop Protection Association. United States
pesticide producers benefit from a highly developed chemical sector and
strong demand from developing regions of the world. Nevertheless, export
opportunities are being restrained by industry-wide globalization as producers
are choosing to site facilities closer to end-use markets. In addition,
regulatory reforms in Western Europe, such as the competitive access
provider plan, are expected to limit prospects in that region, currently the
largest destination for United States produced pesticides (USDOC, 1998).
International competition for the United States phosphatic fertilizer industry
generally comes from countries with phosphate rock reserves and capacity to
convert rock into phosphate chemicals. Diammonium phosphate imports are
expected to account for most of the growth in world trade, thus giving the
United States a promising outlook for this product. Morocco possesses at
least 50 percent of the world's rock reserves and is the largest phosphate rock
exporter. China and Russia are also major phosphate rock and fertilizer
producers, with Russia also a leading exporter of phosphate chemicals. In the
world pesticide markets, maj or competitors are companies based in Germany,
France, and Switzerland.
The United States is a net importer of nitrogenous fertilizers. Trinidad and
Tobago and Canada are the leading United States suppliers of nitrogen due
to their low-cost supplies of natural gas.
Agricultural biotechnology is beginning to play a major role in agricultural
pest control, spurred on by government pesticide restrictions, increased insect
resistance to pesticides, and farmers' demand for productivity gains.
Genetically engineered plants will be higher yielding, more resistant to
disease and insects, and tolerant to herbicides. A number of companies have
received approvals for the use of genetically engineered seeds, including corn
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and cotton, that are resistant to insects and herbicide tolerant. Commercial
usage should increase rapidly over the next few years (USDOC, 1998).
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III. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the Fertilizer,
Pesticide, and Agricultural Chemical Industry, including the materials and
equipment used, and the processes employed. The section is designed for
those interested in gaining a general understanding of the industry, and for
those interested in the inter-relationship between the industrial process and
the topics described in subsequent sections of this profile ~ pollutant
outputs, pollution prevention opportunities, and federal regulations. This
section does not attempt to replicate published engineering information that
is available for this industry. Refer to Section IX for a list of resource
materials and contacts that are available.
This section specifically contains a description of commonly used
production processes, associated raw materials, the by-products produced or
released, and the materials either recycled or transferred off-site. This
discussion, coupled with schematic drawings of the identified processes,
provide a concise description of where wastes may be produced in the
process. This section also describes the potential fate (via air, water, and
soil pathways) of these waste products.
The three most important nutrients for plant growth are nitrogen,
phosphorous, and potassium. However, the production of the major
potassium fertilizer salts, or potash as they are commonly known, is typically
considered an inorganic chemical process (SIC 2819). Therefore, the
discussion of fertilizer production in this notebook is restricted to nitrogenous
and phosphatic mixtures. The fertilizer, pesticide, and agricultural chemical
industry can be divided into Nitrogenous Fertilizers, Phosphatic Fertilizers,
Fertilizers (Mixing-only), and the formulating and preparing of pesticides and
other agricultural chemicals. A detailed description of the production
processes for nitrogenous and phosphatic fertilizers is presented here, along
with brief descriptions of the fertilizer mixing and pesticide formulating and
preparing industry.
III.A. Nitrogenous Fertilizers
The major nitrogenous fertilizers include synthetic ammonia, ammonium
nitrate, and urea. The various industrial processes used to manufacture these
products are described, as well as the production process for nitric acid, an
important intermediate hi nitrogenous fertilizer production.
III.A.1. Synthetic Ammonia
Synthetic ammonia (NH3) is produced by reacting hydrogen with nitrogen at
a molar ratio of three to one. Nitrogen is obtained from the air, which is
primarily comprised of nitrogen (78 percent) and oxygen (21 percent) (Lewis,
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1993). Hydrogen is obtained from either the catalytic steam reforming of
natural gas (methane) or naptha, or as the byproduct from the electrolysis of
brine at chlorine plants. In the United States, about 98 percent of the
hydrogen used to synthesize ammonia is produced by catalytic steam
reforming of natural gas, and only 2 percent is obtained from chlorine plants
(USEPA, 1993a).
Six process steps are required to produce synthetic ammonia using the
catalytic steam reforming method:
1) natural gas desulfurization
2) catalytic steam reforming
3) carbon monoxide shift
4) carbon dioxide removal
5) methanation
6) ammonia synthesis.
The first, third, fourth, and fifth steps remove impurities such as sulfur, CO,
CO2 and water from the feedstock, hydrogen and synthesis gas streams. In the
second step, hydrogen is manufactured and mixed with air (nitrogen). The
sixth step produces anhydrous ammonia from the synthetic gas. An
anhydrous compound is inorganic and does not contain water either adsorbed
on its surface or combined as water of crystallization. While almost all
ammonia plants use these basic process steps, details such as operating
pressures, temperatures, and quantities of feedstock vary from, plant to plant.
Figure 7 shows a simplified process flow diagram of a typical ammonia plant
(USEPA, -1993a).
Natural gas desulfurization
In the natural gas desulfurization step, the sulfur content (primarily as H2S)
in natural gas feedstock is reduced to below 280 micrograms per cubic meter
to prevent poisoning of the catalyst used in the catalytic steam reforming step.
Desulfurization can be accomplished by passing the natural gas through a bed
of either activated carbon or zinc oxide. In both systems, the hydrogen sulfide
in the gas adsorbs to the surface of the activated carbon or zinc oxide medium
and the desulfurized natural gas passes through.
Over 95 percent of the ammonia plants in the United States use activated
carbon fortified with metallic oxide additives for feedstock desulfurization.
After a certain amount of impurities adsorb to the activated carbon, its
effectiveness is reduced and it must be regenerated by passing superheated
steam through the carbon bed. The superheated steam strips out the sulfur
impurities, is condensed, and sent to the wastewater treatment plant. One
disadvantage of the activated carbon system is that some of the heavy
hydrocarbons in the natural gas adsorb to the carbon, decreasing its
effectiveness and lowering the heating value of the desulfurized gas.
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The remaining five percent of plants use zinc oxide for desulfurization. The
zinc oxide system is capable of absorbing up to 20 percent sulfur by weight
Figure?: Typical Process of Ammonia Synthesis
NATURAL GAS
FEEDSTOCK
DESULFURIZATION
FUEL
STEAM
PRIMARY REFORMER
AIR
SECONDARY
REFORMER
VOC
EMISSIONS
PROCESS
CONDENSATE^_
STEAM WASTEWATER
TO TREATMENT
PURGE GAS VENTED TO
PRIMARY REFORMER
FOR FUEL
HIGH TEMPERATURE
SHIFT
LOW TEMPERATURE
SHIFT
C02 '
ABSORBER
METHANATION
FINISHED NH,-*-
AMMONIA SYNTHESIS
T
EMISSIONS
DURING CARBON
REGENERATION
FUEL COMBUSTION
EMISSIONS
C02
EMISSIONS
C02 SOLUTION
REGENERATION
STEAM WASTEWATER
TO TREATMENT
CATALYTIC
AMMONIA SYNTHESIS
LET-DOWN
SEPARATOR
Source: United States EPA, 1993a.
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(Hodge, 1 994). Zinc oxide is replaced rather than regenerated, which lowers
energy consumption and minimizes impact to the atmosphere. The higher
molecular weight hydrocarbons are not removed; therefore, the heating value
of the natural gas is not reduced. However, it is impractical and
uneconomical to replace the zinc oxide beds so few plants use it (USEPA,
1993a).
Catalytic steam reforming
Next, the desulfurized natural gas is preheated by mixing with superheated
steam. The mixture of steam and gas enters the primary reformer tubes
which are filled with a nickel-based reforming catalyst, and the tubes are
heated by natural gas or oil-fired burners. Approximately 70 percent of the
methane (CH4) is converted to hydrogen (H2) and carbon dioxide (CO 2),
according to the following reaction:
0.88CH4 + 1.26air + 1.24 H2O - 0.88 CO2 +N2 + 3H2
The remainder of the CH4 is converted to H2 and CO. This process gas is then
sent to the secondary reformer, where it is mixed with compressed hot air at
540°C (1004°F). Sufficient air is added to produce a final synthesis gas
having a hydrogen-to-nitrogen mole ratio of three to one. The gas leaving the
secondary reformer (primarily hydrogen, nitrogen, CO, CO2, and H20) is then
cooled to 360°C (680°F) in a waste heat boiler before being sent to the
carbon monoxide shift (USEPA, 1993a).
Carbon monoxide shift
After cooling, the secondary reformer effluent gas enters a high temperature
(350-400°C) CO shift converter which converts the CO to CO2, followed by
a low temperature (200-250°C) shift converter which continues to convert
CO to CO2 (Kroschwitz and Howe-Grant, 1992). The high temperature CO
shift converter is filled with chromium oxide initiator and iron oxide catalyst.
The following reaction takes place (USEPA, 1993a):
CO + H2O - CO2
H
The exit gas is then cooled in a heat exchanger before being sent to a low
temperature shift converter for ammonia, amines, and methanol where CO
continues to be converted to CO2 by a copper oxide/zinc oxide catalyst (Kent,
1992). In some plants, the gas is first passed through a bed of zinc oxide to
remove any residual sulfur contaminants that would poison the low
temperature shift catalyst. In other plants, excess low temperature shift
catalyst is added to ensure that the unit will operate as expected. Final shift
gas from this converter is cooled from 210 to 110°C (410 to 230°F) and
unreacted steam is condensed and separated from the gas in a knockout drum.
The final shift gas then enters the bottom t>f the carbon dioxide absorption
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system. The condensed steam (process condensate) contains ammonium
carbonate ([(NH4)2 CO3 • H2O]) from the high temperature shift converter,
methanol (CH3OH) from the low temperature shift converter, and small
amounts of sodium, iron, copper, zinc, aluminum and calcium. Process
condensate is sent to the stripper to remove volatile gases such as ammonia,
methanol, and carbon dioxide. Trace metals remaining in the process
condensate are typically removed in an ion exchange unit (USEPA, 1993a).
Carbon dioxide removal
In this step, CO2 in the final shift gas is removed. CO2 removal can be done
by using one of two methods: monoethanolamine (C2H4NH2OH) scrubbing
or hot potassium scrubbing. Approximately 8 0 percent of the ammonia plants
use monoethanolamine (MEA) for removing CO2. In this process, the CO2
gas is passed upward through an adsorption tower countercurrent to a 15
percent to 30 percent solution of MEA in water fortified with corrosion
inhibitors. After absorbing the CO2, the amine-CO2 solution is preheated and
regenerated in a reactivating tower. The reacting tower removes CO2 by
steam stripping and then by heating. The CO2 gas (98.5 percent CO2) is either
vented to the atmosphere or used for chemical feedstock in other parts of the
plant complex. The regenerated MEA is pumped back to the absorber tower
after being cooled in a heat exchanger and solution cooler (USEPA, 1993a).
i
Methanation
Carbon dioxide absorption is not 100 percent effective in removing CO2 from
the gas stream, and CO2 can poison the synthesis converter. Therefore,
residual CO2 in the synthesis gas must be removed by catalytic methanation.
In a reactor containing a nickel catalyst and at temperatures of 400 to 600 ° C
(752 to 1112°F) and pressures up to 3,000 kPa (435 psia) methanation
follows the following reaction steps:
CO2 + H2 - CO + H2 O
CO + 3H2 - CH4 + H2O
CH4 + 2H20 -CO2 + 4H2
Exit gas from the methanator is almost a pure three to one mole ratio of
hydrogen to nitrogen (USEPA, 1993a).
Ammonia Synthesis
In the synthesis step, the hydrogen and nitrogen synthesis gas from the
methanator is converted to ammonia.
N2 +3H2 -> 2NH3
First, the gas is compressed to pressures ranging from 13,800 to 34,500 kPa
(2000 to 5000 psia), mixed with recycled synthesis gas, and cooled to 0°C
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(32°F). This results in a portion of the gas being converted to ammonia
which is condensed and separated from the unconverted synthesis gas in a
liquid-vapor separator and sent to a let-down separator. The unconverted
synthesis gas is further compressed and heated to 180°C (356°F) before
entering a synthesis converter containing an iron oxide catalyst. Ammonia
gas exiting the synthesis converter is condensed and separated, then sent to
the let-down separator. A small portion of the overhead gas is purged to
prevent the buildup of inert gases such as argon in the circulating gas system.
Ammonia in the let-down separator is flashed to atmospheric pressure (100
kPa(14.5 psia)) at -33 °C (-27 °F) to remove impurities from the make-up gas.
The flash vapor is condensed in a let-down chiller where anhydrous ammonia
is drawn off and stored at low temperature (USEPA, 1993a).
Storage and Transport
Ammonia is typically stored at ambient pressure and -33 °C (-28 °F) in large
20,000 ton tanks. Some tanks are built with a double wall to minimize
leakage and insulate. If heat leaks into the tank and ammonia is vaporized, the
vapors are typically captured, condensed, and returned to the tank. Ammonia
is mostly transported by barge to key agricultural areas, but there is also a
small system of interstate ammonia pipelines (Kent, 1992).
HI.A.2. Nitric Acid
Nitric acid (FfNO3) is produced by two methods. The first method utilizes
oxidation, condensation, and absorption of ammonia to produce a "weak"
nitric acid. Weak nitric acid has a concentration ranging from 30 to 70
percent nitric acid. The second method combines dehydrating, bleaching,
condensing, and absorption to produce "high strength" nitric acid from weak
nitric acid. High strength nitric acid generally contains more than 90 percent
nitric acid (USEPA, 1993a). The following text discusses each of these
processes.
Weak Nitric Acid Production
Nearly all the weak nitric acid produced in the United States is manufactured
by the high temperature catalytic oxidation of ammonia as shown
schematically in Figure 8. This pro'cess typically consists of three steps:
1) ammonia oxidation
2) nitric oxide oxidation
3) absorption.
Each step corresponds to a distinct chemical reaction.
Ammonia Oxidation
During ammonia oxidation, a one to nine ammonia to air mixture is oxidized
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at a temperature of 750 to 800°C (1380 to 1470°F) as it passes through a
catalytic converter, according to the following reaction:
4NH3 + 5O2 - 4NO + 6H£>
The most commonly used catalyst is made of gauze squares of fine wire
constructed of 90 percent platinum and 10 percent rhodium. Under these
conditions the oxidation of ammonia to nitric oxide (NO) proceeds in an
exothermic reaction with 93 to 98 percent yield. Higher catalyst temperatures
increase reaction selectivity toward nitric oxide (NO) production. Lower
catalyst temperatures tend to be more selective toward nitrogen (N2) and
nitrous oxide (N2O) (USEPA, 1993a). The nitric oxide then passes through
a waste heat boiler and a platinum filter in order to recover the precious metal
platinum (Kent, 1992).
Nitric Oxide Oxidation
The nitric oxide formed during the ammonia oxidation is further oxidized in
another process step. The nitric oxide process stream is passed through a
cooler/condenser and cooled to 38°C (100°F) or less at pressures up to 800
kPa (116 psia). The nitric oxide reacts noncatalytically with residual oxygen
to form nitrogen dioxide and its liquid dimer, dinitrogen tetroxide:
2NO + O,
2NO, ->.
(A dimer is a small polymer whose molecule is composed of two molecules
of the same composition (Lewis, 1993).) This slow, homogeneous reaction
is temperature and pressure dependent. Operating at low temperatures and
high pressures promotes maximum production of NO2 within a minimum
reaction time (USEPA, 1993a).
Nitrogen dioxide absorption
The final step introduces the gaseous nitrogen dioxide/dimer mixture into an
absorption process after being cooled. The mixture is pumped into the
bottom of an absorption tower with trays, while liquid dinitrogen tetroxide
(N2O4) is added at a higher point. Deionized water enters the top of the
column. Both liquids flow countercurrent to the dioxide/dimer gas mixture.
The exothermic reaction occurs as follows (USEPA, 1993a):
3NO2 +
H20
2HNO, + NO
A secondary air stream is introduced into the column to re-oxidize the NO
that is formed. This secondary air also removes NO2 from the product acid.
Oxidation of NO to NO2 takes place in the free space between the trays, while
absorption of NO2 into the water occurs on the trays. An aqueous solution of
55 to 65 percent (typically) nitric acid is withdrawn from the bottom of the
tower. The acid concentration can vary from 30 to 70 percent nitric acid
depending upon the temperature, pressure, number of absorption stages, and
concentration of nitrogen oxides entering the absorber (USEPA, 1993a).
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There are two variations of the process described above to produce weak
nitric acid: single-stage pressure process and dual-stage pressure process. In
the past, nitric acid plants have been operated at a single pressure, ranging
from atmospheric pressure to 1400 kPa (14.7 to 203 psia). However, since
the oxidation of ammonia is favored by low pressures and the oxidation of
nitric oxide and the absorption of nitrogen dioxide are favored by higher
pressures, newer plants tend to operate a dual-stage pressure system,
incorporating a compressor between the ammonia oxidizer and the condenser.
The oxidation reaction is carried out at pressures from slightly negative to
about 400 kPa (58 psia), and the absorption reactions are carried out at 800
to 1,400 kPa (116 to 203 psia) (USEPA, 1993a).
In the dual-stage pressure system, the nitric acid formed in the absorber
(bottoms) is usually sent to an external bleacher where air is used to remove
(bleach) any dissolved oxides of nitrogen (NO, NO2, etc.). The bleacher
gases are then compressed and again passed through the absorber. The
absorber tail gas (distillate) is sent to an entrainment separator for acid mist
removal. Next, the tail gas is reheated in the ammonia oxidation heat
exchanger to approximately 200°C (392°F). The gas is then passed through
catalytic reduction units for NOX emissions control. The final step expands
the gas in the power-recovery turbine. The thermal energy produced in this
turbine can be used to drive the compressor.
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Figure 8; Typical Process of Dual-Stage, Weak Nitric Acid Production
TO ATMOSPHERE
A.
ENTRAINED
MIST
SEPERATOR
LIQUID
DINITROGEN
TETROXIDE
COMPRESSOR
WASTE COOLING
WATER
HN03
30-70%
HNO3
AIR
Source: United States EPA, 1993a.
High Strength Nitric Acid
High strength nitric acid (98 to 99 percent concentration) can be obtained by
concentrating weak nitric acid (30 to 70 percent concentration) using
extractive distillation. Extractive distillation is distillation carried out in the
presence of a dehydrating agent. Concentrated sulfuric acid (typically 60
percent sulfuric acid) is most commonly used for this purpose. The weak
nitric acid cannot be concentrated by simple fractional distillation, in which
acid is concentrated by removing water vapor in a column with trays or
plates.
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The nitric acid concentration process consists of feeding strong sulfuric acid
and 55 to 65 percent nitric acid into the top of a packed dehydrating column
at approximately atmospheric pressure. The acid mixture flows downward
and concentrated nitric acid leaves the top of the column as 99 percent vapor,
containing a small amount of NO2 and O2 resulting from dissociation of nitric
acid. The concentrated acid vapor then goes to a bleacher and a
countercurrent condenser system to condense strong nitric acid and the
separate out the oxygen and nitrogen oxide by-products. The bleacher uses
air to strip nitrogen oxides out of the nitric acid and the countercurrent
condenser system cools the vapor by flowing air through the vapor causing
droplets to separate out.
These nitrogen oxide by-products .then flow to an absorption column where
the nitric oxide mixes with auxiliary air to form NO2, which is recovered as
weak nitric acid. Inert and unreacted gases are vented to the atmosphere from
the top of the absorption column. Emissions from this process are relatively
small compared to weak acid production (USEPA, 1993a). Figure 9
illustrates a typical high strength nitric acid production process.
Figure 9: Typical Process Diagram of High Strength Nitric Acid Production
55-65%
HN03
99% HNO3, NO2, O2
AIR, NOXTO
ATMOSPHERE
60%
H2SO4
BLEACHER
CONDENSER
WEAK HN03
Source: Adapted from United States EPA, 1993a.
III.A.3. Ammonium Nitrate and Urea
The manufacture steps for ammonium nitrate (NH4NO2) and urea (CO(NH2)2)
are similar. In both cases, several major unit operations are involved,
including:
1) solution formation
2) concentration ,
3) solids formation
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4) finishing
5) screening
6) coating
7) product bagging and/or bulk shipping.
These operations are shown schematically in Figure 10. Not all steps are
always necessary depending on the end product desired. For example, plants
producing ammonium nitrate or urea liquid solutions alone use only the
solution formation, solution blending and bulk shipping operations. Plants
producing a solid product may employ all of the operations.
Solution synthesis
Ammonium nitrate.
Ammonium nitrate plants produce an aqueous ammonium nitrate solution
through the reaction of ammonia and nitric acid in a neutralizer where water
is evaporated by the heat of the reaction as follows:
NH3 + HNO3
NH4NO3
26 kcal/g mol
The temperature, pressure, and final concentration of the ammonium nitrate
are interdependent. Higher temperatures and pressures can be used to
produce a higher concentration of ammonium nitrate (Hodge, 1994);
however, the temperature of the operation should be below 120°C (250°F)
in order to prevent explosions. Up to 99.5 percent of the ammonia and nitric
acid is typically converted to ammonium nitrate (Kent, 1992). Ammonium
nitrate solution can then be used as an ingredient for nitrogen solution
fertilizers or concentrated to a solid form.
Urea.
In the urea solution synthesis operation, ammonia (NH3) and carbon dioxide
(CO2) are reacted to form ammonium carbamate (NH 2CO 2NH 4) as follows:
2NH + CO
NH2C02NH4
Typical operating conditions include temperatures from 180 to 200°C (356
to 392°F), pressures from 14,000 to 25,000 kPa (140 to 250 psia), molar
ratios of NH3 to CO2 from 3:1 to 4:1, and a retention time of twenty to thirty
minutes. The ammonium carbamate is then dehydrated to yield 70 to 77
percent aqueous urea solution. This reaction follows: (USEPA, 1993a)
NH2CO2NH4 - NH2CONH2 + H2O
Urea solution can be used as an ingredient of nitrogen solution fertilizers, or
it can be concentrated further to produce solid urea.
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Solids Concentration
Ammonium nitrate.
To produce a solid product, the aqueous ammonium nitrate solution is
concentrated in an evaporator or concentrator. The resulting liquid "melt"
contains about 95 to 99.8 percent ammonium nitrate at approximately 149 °C
(300°F). This melt is then used to make solid ammonium nitrate products
(USEPA, 1993a).
Urea.
The three methods of concentrating the urea solution are vacuum
concentration, crystallization, and atmospheric evaporation. The method
chosen depends upon the level of biuret (NH2CONHCONH2) impurity
allowable hi the end product. Biuret can cause mottling in urea solutions,
reducing the fertilizers effectiveness in foliar applications (Kent, 1992).
Aqueous urea solution decomposes with heat to biuret and ammonia.
Therefore, if only a low level of biuret impurity is allowed in the end product,
the method with the least heat requirement will be chosen, such as
.crystallization and vacuum concentration (Kent, 1992). However, the
simplest and most common method of solution concentration is atmospheric
evaporation.
Solids Formation
Prilling and granulation are the most common processes used to produce
solid ammonium nitrate and urea. Prills are round or needle-shaped
artificially prepared aggregates of a material. To produce prills, concentrated
melt is sprayed into the top of a prill tower. In the tower, melt droplets fall
countercurrent to a rising air stream that cools and solidifies the falling
droplets into prills. Prill density can be varied by using different
concentrations of ammonium nitrate melt. Low density prills, in the range of
1.29 specific gravity, are formed from a 95 to 97.5 percent ammonium nitrate
melt, and high density prills, in the range of 1.65 specific gravity, are formed
from a 99.5 to 99.8 percent melt. Low density ammonium nitrate prills are
used for making blasting agents because they are more porous than high
density prills and will absorb oil. Most high density prills are used as
fertilizers (USEPA, 1993a).
Granulated ammonium nitrate and urea are produced by spraying a
concentrated melt (99.0 to 99.8 percent) onto small seed particles of
ammonium nitrate or urea in a long rotating cylindrical drum. As the seed
particles rotate in the drum, successive layers of the nitrogenous chemical are
added to the particles, forming granules. Pan granulators operate on the same
principle as drum granulators, except the solids are formed in a large, rotating
circular pan. Pan granulators produce a solid product with physical
characteristics similar to those of drum granules (USEPA, 1993 a).
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Although not widely used, additives such as magnesium nitrate or magnesium
oxide may be injected directly into the melt stream. Additives can serve three
purposes: to raise the crystalline transition temperature of the final solid
product in order to retain its strength and density; to act as a desiccant,
drawing water into the final product to reduce caking; and to allow
solidification to occur at a low temperature by reducing the freezing point of
molten ammonium nitrate. (Kent, 1992)
Solids Cooling
The temperature of the nitrogenous product exiting the solids formation
process is approximately 66 to 124°C (150 to 255°F). To prevent
deterioration and agglomeration, the product must be cooled before storage
and shipping. Typically, rotary drums or fluidized beds are used to cool
granules and prills leaving the solids formation process. Because low density
prills have a high moisture content, they require drying in rotary drums or
fluidized beds before cooling (USEPA, 1993a).
Solids Screening
Since the solids are produced in a wide variety of sizes, they must be
screened for consistently sized prills or granules. After cooling, off size prills
are dissolved and recycled back to the solution concentration process.
Granules are screened before cooling. Undersize particles are returned
directly to the granulator and oversize granules may be either crushed and
returned to the granulator or sent to the solution concentration process
(USEPA, 1993a)..
Solids Coating
Following screening, products can be coated in a rotary drum to prevent
agglomeration during storage and shipment. The most common coating
materials are clays and diatomaceous earth. However, the use of additives in
the melt before solidification may preclude the use of coatings.
The solid product is stored and shipped in either bulk or bags. The majority
of solid product is bulk shipped in trucks, enclosed railroad cars, or barges,
and approximately ten percent of solid ammonium nitrate and urea produced
in the United States is bagged (USEPA, 1993a).
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Figure 10: Typical Process for Ammonium Nitrate and Urea Manufacturing
PARTICULATES
WASTEWATER •*
AMMONIA-
CARBON _
DIOXIDE
Source: United States EPA, 1993a.
III.B. Phosphatic Fertilizers
The primary products of the phosphatic fertilizers industry are phosphoric
acid, ammonium phosphate, normal superphosphate, and triple
superphosphate. Phosphoric acid is sold as is or is used as an intermediate in
producing other phosphatic fertilizers. Monoammonium phosphate is
favored for its high phosphorous content, while diammonium phosphate is
favored for its high nitrogen content. Normal superphosphate has a relatively
low concentration of phosphorous, however it is used in mixtures because of
its low cost. Triple superphosphate provides a high concentration of
phosphorous, more than 40% phosphorous pentoxide. The industrial
processes for each of these products are described below.
III.B.l. Phosphoric Acid (Wet Process)
In a wet process phosphoric acid facility (shown schematically in Figure 11),
phosphoric acid is produced by reacting sulfuric acid (H2SO4) with naturally
occurring phosphate rock. The phosphate rock is mined, dried, crushed until
60 to 70 percent of the rock is less than 150 pum. in diameter, and then
continuously fed into the reactor along with sulfuric acid (UNEP, 1996). The
reaction also combines calcium from the phosphate rock with sulfate,
forming calcium sulfate (CaSO4), commonly referred to as gypsum. Gypsum
is separated from the reaction solution by filtration.
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Facilities in the United States generally use a dihydrate process that produces
gypsum in the form of calcium sulfate with two molecules of water (CaSO4
• 2H 2O or calcium sulfate dihydrate). Japanese phosphoric acid facilities use
a hemihydrate process which produces calcium sulfate with a half molecule
of water (CaSO4 • Vz H 2O). This one-step hemihydrate process has the
advantage of producing wet process phosphoric acid with a higher phosphate
pentoxide (P2O5) concentration and less impurities than the dihydrate process .
Due to these advantages, some United States companies have recently
converted to the hemihydrate process. However, since most wet process
phosphoric acid is still produced by the dihydrate process, the hemihydrate
process will not be discussed in detail here.
A simplified reaction for the dihydrate process is as follows:
+ 3H2S04 + 6H20 - 2H3PO4 + 3[CaSO4 • 2H2O]I
To make the strongest phosphoric acid possible and to decrease evaporation
costs, a highly concentrated 93 percent sulfuric acid is normally used.
Because the proper ratio of acid to rock in the reactor is critical, precise
automatic process control equipment is employed in the regulation of these
.two feed streams (USEPA, 1993a).
During the reaction, gypsum crystals are precipitated and separated from the
acid by filtration. The separated crystals must be washed thoroughly to yield
at least a 99 percent recovery of the filtered phosphoric acid. After washing,
the slurried gypsum is pumped into a gypsum settling pond for storage. Water
is siphoned off and recycled through a surge cooling pond to the phosphoric
acid process. Depending on a variety of factors, such as average ambient
temperature and annual rainfall, settling and cooling ponds may require
between 0.25 and 1.0 acre for each ton of daily P205 capacity (TFI, 1999).
Considerable heat is generated in the reactor when the sulfuric acid and
phosphate rock react. In older plants, this heat was removed by blowing air
over the hot slurry surface. Modern plants vacuum flash cool a portion of the
slurry, and then recycle it back into the reactor.
Wet process phosphoric acid normally contains 26 to 30 percent P2O5. In
most cases, the acid must be further concentrated to meet phosphate feed
material specifications for fertilizer production. Depending on the types of
fertilizer to be produced, phosphoric acid is usually concentrated to 40 to 55
percent P2O5 by using two or three vacuum evaporators (USEPA, 1993a).
These evaporators operate with a forced circulation and generate a vacuum
through vacuum pumps, steam ejectors, or an entraining condenser
downstream of the evaporator. Figure 12 illustrates a vacuum evaporator.
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Figure 11; Typical Process of a Wet Process Dihydrate Phosphoric Acid Plant
PHOSPHATE
ROCK
WEIGH
FEEDER
^. \ -^.
^"
SULFURIC
ACID ^
~~i
/\ VACUUM
FLASH
COOLER
\ / WATER
\/
y v A
REACTOR •*• GYPSUM ^. CRYSTAL
' """'"" ^ FILTRATION *"~ WASHES
1
PHOSPHORIC
ACID (26-30%)
A
^. SETTLING
"^ POND
1
GYPSUM
Source: Adapted from United States EPA, 1993 a.
Figure 12: Typical Vacuum Evaporator Process
TO ACID PLANT -«
TO VACUUM
AND HOT WELL
HYDROFLUOSILJC ACID
Source: United States EPA, 1993a
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III.B.2. Ammonium Phosphate
Diammonium phosphate (DAP) and monoammonium phosphate are the
major types of ammonium phosphatic fertilizer. Ammonium phosphates are
produced by reacting phosphoric acid with ammonia. The ammonium
phosphate liquid slurry produced is then converted to solid granules.
Approximately 95 percent of ammoniation-granulation plants in the United
States use a rotary drum mixer developed and patented by the Tennessee
Valley Authority (TVA).
In the TVA DAP process, phosphoric acid is mixed in an acid surge tank with
93 percent sulfuric acid (H2SO4) and recycled acid from wet scrubbers. The
mixed acids are then partially neutralized with liquid or gaseous anhydrous
ammonia in a brick-lined acid reactor. All of the phosphoric acid and
approximately 70 percent of the ammonia needed to complete the reaction are
introduced into this vessel. A slurry of ammonium phosphate and 22 percent
water are produced and sent through steam-traced lines to the ammoniator-
granulator.
Slurry from the reactor is distributed in the rotary drum granulator, and the
remaining ammonia (approximately 30 percent) is sparged under the slurry.
The basic rotary drum granulator consists of an open-ended, slightly inclined
rotary cylinder, with retaining rings at each end and a scraper or cutter
mounted inside the drum shell. A rolling bed of dry material is maintained
in the unit while the slurry is introduced through distributor pipes set
lengthwise in the drum. Gravity forces the slurry to travel through the turning
granulator to the lower end. Moist DAP granules are then discharged into a
rotary dryer, where excess water is evaporated and the chemical reaction is
accelerated to completion by the dryer heat. Dried granules are cooled and
then sized on vibrating screens. The product ranges in granule diameter from
one to four millimeters (mm). The oversized granules are crushed, mixed
with the undersized, and recycled back to the ammoniator-granulator.
Product-size DAP granules are allowed to cool, screened, bagged, and
shipped. Before being exhausted to the atmosphere, particulate and ammonia
rich off-gases from the granulator, cooler, and screening operations pass
through cyclones and wet scrubbers (USEPA, 1993a).
TVA developed two minor modifications in their DAP process to produce
Monoammonium Phosphate (MAP). In one, the phosphoric acid is
ammoniated to an ammonia to phosphoric acid ratio of only 0.6 in the
preneutralizer and then 1.0 in the granulator. This compares to a ratio of
about 1.4 for DAP. With the second modification, the ammonium to
phosphoric acid ratio is brought to 1.4 in the preneutralizer, then additional
phosphoric acid is added in the granulator to bring the ratio back to 1.0. The
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second method is preferred by industry because higher temperatures may be
used to dry the MAP,'increasing production rates (Kent, 1992).
(
A schematic diagram of the ammonium phosphate process flow diagram is
shown in Figure 13.
Figure 13: Simplified Process Flow Diagram of Diammnonium Phosphate Production
GYPSUM
POND
WATER
4
\
JL
<
PHOSPHORIC.
ACID
SULFURIC
ACID
ANHYDROUS
AMMONIA
/CYCLONE
OVERSIZE
COOLING AIR
MILL
AMMONIATOR
GRANULATi
DUST
SUPPRESSANT
PRODUCT
UNDERSIZE
DUST
SUPPRESSANT
Source: U.S.EPA, 1993aandTFI, 1999
III.B.3. Normal Superphosphate
Normal superphosphates (NSP) are prepared by reacting ground phosphate
rock with 65 to 75 percent sulfuric acid to produce a solid fertilizer material.
NSP is most often used as a high-phosphate additive in the production of
granular fertilizers. It can also be granulated for sale as granulated
superphosphate or granular mixed fertilizer.
There are two primary types of sulfuric acid used in superphosphate
manufacture: virgin and spent acid. Virgin acid is produced from elemental
sulfur, pyrites, and industrial gases and is relatively pure. Spent acid is a
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recycled waste product from various industries that use large quantities of
sulfuric acid. Problems encountered with using spent acid include unusual
color, unfamiliar odor, and toxicity. An important factor in the production
of normal superphosphates is the amount of iron and aluminum in the
phosphate rock. Aluminum (as A12O3) and iron (as Fe2O3) above five percent
imparts an extreme stickiness to the superphosphate and makes it difficult to
handle (USEP A, 1993a).
A generalized process diagram of normal superphosphate production is
shown in Figure 14. Ground phosphate rock is weighed and mixed with
sulfuric acid (H2SO4) and held in an enclosed area for about 30 minutes until
the reaction is partially completed. The mixing may be done in a cone mixer,
which relies on an inputted swirling motion of the acid to mix the rock and
acid, a pug mill, which operates with one or two mixing shafts, or a pan
mixer, which agitates the solution. The reaction is (AWMA, 1992): •
CaIO(PO4)6F2CaCO3
1 1H2SO4 - 6H3PO4
2HF + CO2 + H2O
!CaSO4*nH2O
The mixture is then transferred, using an enclosed conveyer known as the
den, through the cutter which breaks up clumps, and finally to a storage pile
for curing. Off-gases from the reactor are typically treated in a wet scrubber.
Particulates throughout the process are controlled with cyclones and
baghouses (USEP A, 1993a).
To produce granulated normal superphosphate, cured superphosphate is fed
through a clod breaker and sent to a rotary drum granulator where steam,
water, and acid may be added to aid in granulation. Material is processed
through a rotary drum granulator, a rotary dryer, and a rotary cooler, and is
then screened to specification similar to the process used for ammonium
nitrate and urea. Finally, it is stored in bagged or bulk form prior to being
sold (USEP A, 1993a).
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Figure 14: Typical Process for Normal Superphosphate Manufacturing
Dust
Participate
emissions
Particulate
emissions
To gypsum
pond
Particulate and
fluoride emissions
Particulate and
*- fluoride emissions
(uncontrolled)
Product
Source: United States EPA, 1993a.
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JIII.B.4. Triple Superphosphate
Triple superphosphate provides a high concentration of phosphorous. Two
processes have been used to produce triple superphosphate: run-of-the-pile
(ROP-TSP) and granular (GTSP). GTSP yields larger, more uniform
particles with improved storage and handling properties than ROP-TSP. At
this time, no facilities in the United States are producing ROP-TSP, so only
the GTSP process is described here.
Most GTSP material is made with the Dorr-Oliver slurry granulation process,
illustrated in Figure 15. This process is similar to that for normal
superphosphates with the maj or exception being that phosphoric acid is used
instead of sulfuric acid. In this process, ground phosphate rock or limestone
is reacted with phosphoric acid in one or two reactors in series (USEPA,
1993a). The reaction is:
Ca5F(P04)3+ 7H3P04
5H2O
5Ca(H2PO4)2-H2O +HF
(Hodge, 1 994) The phosphoric acid used in this process has a relatively low
concentration (40 percent P2O5). The lower strength acid maintains the slurry
in a fluid state during a mixing period of one to two hours. A small
sidestream of slurry is continuously removed and distributed onto dried,
recycled fines in a granulator, where it coats the granule surfaces and builds
up its size.
Granules are then dried in a rotary dryer, elevated and passed through screens
to eliminate oversize and undersize granules. Oversize granules are crushed
and sent back to the first screen, while undersize ones are sent into the
emission control systems. The granules within the size range of the product
are then cooled and stored in a curing pile where the reaction is completed.
Particulates from the rock handling, drying, screening, cooling, and storing
processes are typically controlled with cyclones and bag houses and off-gases
from the reactor, granulator, and cyclones and baghouses are typically treated
with wet scrubbers (USEPA, 1993a).
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Figure 15: Typical Process for Triple Superphosphate
Source: United States EPA, 1993a
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III.C. Fertilizer Mixing
A significant part of the fertilizer industry only purchases fertilizer materials
in bulk from fertilizer manufacturing facilities and mixes them to sell as a
fertilizer formulation. Fertilizer mixing facilities use many different
materials in their blends. The most common granular fertilizer materials are
listed in Table 9.
Table 9: Fertilizer Materials Used in Bulk Blends
Ammonium nitrate
Urea
Ammonium sulfate
Diammonium phosphate (DAP)
Monoammonium phosphate (MAP)
Triple Superphosphate
Normal superphosphate
Potassium chloride
Typical Grade
N-P2O5-K20
31-0-0
46-0-0
21-0-0
18-46-0
11-52-0
0-46-0
0-20-0
0-0-60
Percent of
fertilizer plants
using this
material
41%
66%
22%
95%
11%
78%
4%
94%
Source: "Retail Marketing of Fertilizers in the United States, " by Hargett, Norman
and Ralph Pay, 1980.
DAP is favored for fertilizer mixing because of its ease in storage and
handling, convenient low nitrogen and high phosphorous content, and
compatibility with almost any other material. Granular triple superphosphate
is also very popular, but is incompatible with urea, a common nitrogen
source. Therefore, TSP is commonly used in no-nitrogen blends necessary
for legumes. Ammonium sulfate has the lowest nitrogen content of the major
nitrogen sources, however its production cost is quite low. Potassium
chloride is the only major potassium source used in fertilizer blending.
Additional materials may also be added to the blends, such as micronutrients
and pesticides (Nielson, 1987).
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Inert ingredients may also be added to fertilizer mixtures to improve the
consistency or ease of application. Inert ingredients include sands, clays, and
water.
Fertilizer mixing plants consist of five primary phases:
1. mixing and storing
2. moving materials to mixers
3. proportioning of materials
4. mixing, and
5. moving the finished blend to holding bins or transport containers
Fertilizer materials may be mixed as bulk blends or formed into granulations
by a variety of processes. Bulk blending is a dry process, where different
fertilizers are combined. Materials are typically received by rail cars and
transferred through elevators to storage areas. Front-end loaders then carry
the materials to weighing hoppers which feed into the mixers. There are two
types of mixers most commonly used: the horizontal axis rotary drum mixer
and the inclined axis rotary drum mixer. The inclined axis mixer is similar
to a cement mixer in design and appearance. Ribbon-type bulk-blend mixers
are also used in some plants. A ribbon-type mixer has an axial shaft with
mixing spokes radiating out of the shaft in a configuration which forces the
blend to flow in a ribbon-like pattern through the mixture (Nielson, 1987).
After preparation and initial bulk blending of materials, granulation may be
employed in order to form larger fertilizer particles with multi-nutrient
compositions. Granulation of mixed fertilizers may be accomplished by
steam granulation, slurry granulation, melt, or compaction granulation.
Steam granulation is primarily used in Europe and Australia. The process
results in little chemical reaction in order to maintain the P2O5 content of the
fertilizer. Plasticity and agglomeration of the fertilizer materials is promoted
by the injection of steam into rotating pans, rotary drums, or pug mills. The
particles are then dried with heated air in a rotary drum dryer and cooled in
a rotary drum cooler. In some cases, particles may be coated with chalk or
clay to prevent caking (Hoffmeister, 1993).
Slurry granulation is more commonly used in the United States The process
involves a chemical reaction of the feed ingredients. In slurry granulation,
one of the feed ingredients is prepared as a slurry and reacted with the others
in a preneutralizer. The slurry is then fed to a granulator such as the
ammoniator-granulator developed by the TVA. Fertilizer producers in the
United States found that higher concentrations of acid could be fed to this
preneutralizer-granulator process than to a granulator alone, thus increasing
the grades of fertilizers and making the TVA process popular in the United
States (Hoffmeister, 1993).
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Another granulation process similar to slurry granulation is melt granulation.
The slurry feed is replaced by a hot, concentrated, almost anhydrous melt of
feed fertilizer, typically ammonium phosphate, prepared in a pipe reactor.
The hot melt provides the plasticity necessary for granulation. The granules
cool first in the granulator and then in the cooler, eliminating the need for a
dryer.
Compaction granulation is based on the fact that most materials are
semiplastic and when subj ected to high pressures, the materials will compact,
deform, and it is possible to roll them out into flat, stable sheets. These
sheets are then cracked, forming granule-size chips which are most stable and
less prone to caking than other granulations. This process has been
successful for many fertilizer mixtures, particularly those including potassium
chloride and ammonium phosphates and superphosphates. Ammonium
sulfate, however, has limited crystal plasticity, making it unsuitable for
compaction granulation (Hoffmeister, 1993).
The mixtures are then typically bagged in woven polypropylene bags for
strength and resistance, with liner bags to prevent leaks. The bags are either
clamped, tied, heat sealed, or sewn, sewing being the cheapest and most
common method (Nielson, 1987).
III.D. Pesticide Formulating Processes
Pesticide formulation involves the process of mixing, blending, or diluting
one or more pesticide active ingredients (AIs) and inert ingredients to obtain
a product used for additional processing or an end-use (retail) product.
Formulation does not involve an intended chemical reaction (i.e., chemical
synthesis). AIs are produced at separate facilities not included in this
notebook. Pesticide formulations take many forms: water-based liquid;
organic solvent-based liquid; dry products in granular, powder, and solid
forms; pressurized gases; and aerosols. The formulations can be in a
concentrated form requiring dilution before application, or they can be ready
to apply. The packaging of the formulated pesticide product depends on the
type of formulation. Liquids generally are packaged into jugs, cans, or
drums; dry formulations generally are packaged into bags, boxes, drums, or
jugs; pressurized gases are packaged into cylinders; and aerosols are
packaged into aerosol cans.
Formulating, packaging, and repackaging is performed in a variety of ways,
ranging from very sophisticated and automated formulating and packaging
lines to completely manual lines. Descriptions of liquid formulating and
packaging, dry formulating and packaging, aerosol packaging, pressurized
gas formulating and packaging, and repackaging operations are provided
below.
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III.D.l. Liquid Formulating and Packaging
Liquid formulations contain mixtures of several raw materials, including AIs,
inert ingredients such as base solvents, emulsifiers, or surfactants. The
solvent must be able to dissolve the AIs and other ingredients. It may be
water or an organic chemical, such as isopropyl alcohol or petroleum
distillate. In some cases, the formulation is an emulsion and contains both
water and an organic solvent. Solid materials, such as powders or granules,
may also be used as part of a liquid formulation by dissolving or emulsifying
the dry materials to form a liquid or suspension. The formulated product may
be in a concentrated form requiring dilution before application, or may be
ready to apply.
Typical liquid formulating lines consist of storage tanks or containers to hold
active and inert raw materials and a mixing tank for formulating the pesticide
product. A storage tank may also be used on the formulating line to hold the
formulated pesticide product, prior to a packaging step. Facilities may
receive their raw materials in bulk and store them in bulk storage tanks, or
they may receive the raw materials in smaller quantities, such as 55-gallon
drums, 50-pound bags, or 250-gallon minibulk refillable containers or
"totes." These raw materials are either piped to the formulation vessel from
bulk storage tanks or added directly to the vessel from drums, bags, or
minibulks. Typically, water or the base solvent is added to the formulation
vessel in bulk quantities (USEPA, 1996). A typical liquid formulating line
is shown in Figure 16.
The formulating line may also include piping and pumps for moving the raw
material from the storage tanks to the mixing tank, and for moving
formulated pesticide product to the packaging line. Other items that may be
part of the line are premixing tanks, stirrers, heaters, bottle washers, and air
pollution control equipment. Some lines may also have refrigeration units for
formulation and storage equipment, scales, and other equipment.
Many liquid formulations are packaged by simply transferring the final
product into containers. Small quantities of product are often manually
packaged by gravity feeding the product directly from the formulation tank
into the product container. For larger quantities, the process is often
automated. Formulated product is transferred to the packaging line through
pipes or hoses, or is received from a separate formulating facility and placed
in a filler tank. A conveyor belt is used to carry product containers, such as
jugs, bottles, cans, or drums, through the filling unit, where nozzles dispense
the appropriate volume of product. The belt then carries the containers to a
capper, which may be automated or manual, and to a labeling unit. Finally,
the containers are packed into shipping cases (USEPA, 1996).
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Figure 16: Typical Process for Liquid Formulating
RAW MATERIAL
DRUM/BULK TANK
LIQUID PESTICIDE
ACTIVE
INGREDIENT (PAI)
RAW MATERIAL
DRUM/BULK TANK
INERT
INGREDIENTS
/SOLVENTS
/EMULSIFIERS
/SURFACTANTS
OFF-SPECIFICATION
PRODUCT
PACKAGING,
LABELING,
CONTAINER
TESTING &
STORAGE
>
f
FINAL
PACKAGES
PRODUCT
Source: United States EPA, 1996
III.D.2. Dry Formulating and Packaging
Dry formulations also contain active and inert ingredients. The final product
may be in many different forms, such as powders, dusts, granules, blocks,
solid objects impregnated with pesticide (e.g., flea collars), pesticides formed
into a solid shape (e.g., pressed tablets), microencapsulated dusts or granules
(AI coated with a polymeric membrane to prevent premature degradation), or
encapsulated water soluble packaging. They are formulated in various ways,
including:
• mixing powdered or granular AIs with dry inert carriers;
• spraying or mixing a liquid active ingredient onto a dry carrier;
• soaking or using pressure and heat to force active ingredients into a solid
matrix;
• mixing active ingredients with a monomer and allowing the mixture to
polymerize into a solid; and
• drying or hardening an active ingredient solution into a solid form.
These dry pesticide products may be designed to be applied in solid form or
dissolved or emulsified in water or solvent prior to application (USEPA,
1996).
Because there are many types of dry pesticide products, dry pesticide
formulating lines can vary considerably. In general, though, dry formulating
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lines have tanks or containers to hold the active ingredients and inert raw
materials, and may include mixing tanks, ribbon blenders, extruding
equipment, high pressure and temperature tanks for impregnating solids with
active Ingredient, vacuums or other types of drying equipment, tanks or bins
for storage of the formulated pesticide product, pelletizers, presses, milling
equipment, sieves, and sifters (USEPA, 1996).
Raw materials for dry pesticide products may be liquid or solid. Liquid raw
materials may be stored in rail tank cars, tank trucks, minibulks, drums, or
bottles. Dry raw materials may be stored in silos, rail cars, tank trucks,
minibulks, metal drums, fiber drums, bags, or boxes. Liquid raw materials
may be pumped, poured or sprayed into formulation vessels, while dry raw
materials are frequently transferred to formulation equipment by screw
conveyors (consisting of a helix mounted on a shaft and turning in a trough),
elevators, or by pouring.
Dry formulating lines may also include piping and pumps to move raw
materials from storage tanks to the formulation equipment, and to move
formulated pesticide product to the packaging equipment. Other items that
may be included in the dry pesticide product line are premixing tanks, tanks
for storing formulated product prior to packaging, stirrers, heaters,
refrigeration units on formulation and storage equipment, scales, and air
pollution control equipment (e.g., cyclones, filters, or baghouses) (USEPA,
1996).
Dry pesticide products may be packaged into rail tank cars, tank trucks, totes,
and minibulks, but are typically packaged into bags, boxes, and drums. As
with many liquid formulations, dry formulations are packaged by simply
transferring the final product into boxes, drums, jugs, or bags. Small
quantities or bags are typically packaged manually using a gravity feed from
the formulating unit into the containers or bags. Larger quantities may be
packaged on an automated line,ssimilar to liquid packaging lines.
Figure 17 illustrates a dry pesticide formulation line.
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Figure 17: Typical Process for Dry Formulating
RAW MATERIAL DRUM
/BAG/TOTE TANK
DRY PESTICIDE
ACTIVE
INGREDIENT
DRY INERT
INGREDIENTS
DRY
CARRIER
INERT
ATER1AL
LIQUID
PESTICIDE
ACTIVE
INGREDIENT
RAW MATERIAL DRUM
/BULK TANK
FINAL
PACKAGED!
PRODUCT
Source: United States EPA, 1996
III.D.3. Aerosol Packaging
Some pesticide products (typically water-based or solvent-based liquids) are
packaged as aerosols, which can be applied to surfaces or dispersed in the air.
The product is placed in spray cans that are put under pressure and a
propellant is added, which forces the product out of the can in an aerosol
spray. An aerosol packaging line typically includes a filler, a capper, a
propellant injector, and a United States Department of Transportation (DOT)
test bath. In the filler, formulated pesticide product is dispensed into empty
aerosol cans, in much the same way as the liquid packaging lines fill
containers. The cans are then sent to the capper, where a cap with a nozzle is
placed on the can. The can enters a separate room, where the propellent is
injected into the can, a vacuum is pulled, and the cap is crimped to make the
can airtight. In order to comply with DOT regulations on the transport of
pressurized containers, each can must then be tested for leaks and rupturing
in a DOT test bath. Test baths indicate leaks by the appearance of bubbles
at the point of leakage on the cylinder. The aerosol packaging line may also
include a can washer to remove residue from can exteriors prior to entering
the test bath (to reduce contaminant buildup in the bath), a dryer to dry can
exteriors, and machinery to package aerosol cans into boxes for shipment
(USEPA, 1996).
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IILD.4. Pressurized Gas Formulating and Packaging
Some pesticide products are formulated and packaged as pressurized gases,
primarily for the purpose of soil fumigation. Soil fumigation is used where
the nematodic and fungal populations in soil prohibit successful seed
planting. Volatile general toxicants, such as low molecular weight
halogenated compounds, are typically injected into the soil before planting,
but are also occasionally used once plants have reached maturity (Kent,
1992).
The active and inert ingredients are received as liquid, pressurized liquids, or
gases, and are stored in tanks, tank trucks, rail cars, or minibulk storage
containers. Liquid ingredients are placed in a holding tank prior to
formulation. Formulating and packaging operations for these products usually
occurs in one step in a closed-loop system. The ingredients are metered by
weight through pressurized transfer lines into DOT-approved steel
application cylinders. Other equipment that may be included in a pressurized
gas line include pump and piping, and heating and refrigerating units to
maintain gas pressures and temperatures in storage (USEPA, 1996).
The cylinders may be refilled at a later date, after they have been tested to
ensure that they are still capable of containing pressurized fluids. DOT
requires hydrostatic pressure testing, as well as visual examination of the
cylinder (USEPA, 1996).
III.D.5. Repackaging
Repackaging operations are similar to packaging operations, except the "raw
material" is an already formulated product that has been packaged for sale.
Repackagers often purchase formulated pesticide products, transfer the
product to new containers with customer-specific labeling, and sell them to
distributors (USEPA, 1996).
A separate type of repackaging, called refilling, is usually performed by
agrichemical facilities that transfer pesticide products from bulk storage tanks
into minibulks. These refillable containers are typically constructed of plastic
and typically have capacities ranging from 100 to 500 gallons. Minibulks may
be owned by the refilling establishment, the pesticide registrant, or by the end
user. Production lines usually consist of a bulk storage tank, a minibulk tank
into which the product is repackaged, and any interconnecting hoses or
piping. The bulk storage tanks may be dedicated by product and clustered
together in a diked area. The products are dispensed to the minibulks by the
use of manual system or a computer-regulated system of pumps and meters
(USEPA, 1996).
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III.E. Raw Material Inputs and Pollution Outputs
Raw material inputs and pollution outputs of fertilizer products and pesticide
products differ considerably, and, therefore, are discussed separately below.
The pollution outputs are discussed both specifically by product as well as
generally by process since there are some similarities in the fertilizer and
pesticide production processes and pollutant outputs.
III.E.1. Fertilizers
The primary raw materials for fertilizer manufacturing are phosphate rock,
natural gas, sulfuric acid, and carbon dioxide. These materials are combined
by several methods and in different proportions to produce a variety of
fertilizer products, as described in section III.
Figure 18 summarizes the fertilizer material inputs for the principal fertilizer
products.
Figure 18: Raw Material Flowchart for Principal Fertilizer Materials
Source: Adapted from Manual on Fertilizer Statistics, Food and Agriculture Organization of the
United Nations, Rome 1991.
Because the basic fertilizer nutrients are found in many natural and manmade
materials, raw materials for fertilizers can also be derived from sources other
than the virgin materials described above. Common sources of fertilizer
ingredients are sewerage treatment sludges and certain industrial wastes.
Although these waste-derived fertilizers may contain essentially the same
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nutrients as fertilizers derived from virgin materials, they also may contain
additional constituents that were present in the waste material and which may
not be beneficial, or are potentially harmful to crops, human health, or the
environment. Such constituents may enter the food chain or groundwater and
could become concentrated in the soil after repeated use. Lead, cadmium and
arsenic are some of the more common fertilizer ingredients that could be
harmful if sufficient quantities are present. It should be noted, however, that
fertilizers derived from virgin materials also have the potential to contain
harmful levels of these constituents if significant quantities are naturally
present in the raw materials.
One waste material input which has received some attention recently is
cement kiln dust (CKD). Although there has been a considerable amount of
research conducted on CKD use as a fertilizer, existing applications of CKD
for this purpose have been mostly anecdotal, and there is only limited
evidence that commercial CKD use as a fertilizer is growing significantly
(USEPA, 1993b).
Like agricultural lime, CKD is alkaline and contains a number of essential
plant nutrients. Because of these parallel characteristics, CKD has been used
as an agricultural soil amendment. CKD possesses significant fertilizer
potential, particularly because of its high potassium content. Soil scientists
have also suggested that other key plant nutrients contained in CKD, such as
calcium, phosphorous, and zinc, might be beneficial in some fertilizer
applications. However, some concern has been raised over hazardous wastes
in CKD (USEPA, 1993b).
Coal combustion by-products are also receiving attention for their potential
agricultural benefits., including alleviating soil trace elemental deficiencies,
modifying soil pH, and increasing levels of Ca and S, infiltration rates, depth
of rooting, and drought tolerance. Flue gas desulfurization residues, which
contain gypsum, have the potential to improve water use efficiency, product
quality, and productivity of soil-crop systems. The short term benefits of coal
combustion by-products usage has been demonstrated, however, long term
effects have not been documented. Future hazards and benefits are yet to be
determined (Korcak, 1995). Electric-arc furnace dust is also used as a
fertilizer ingredient since it contains a number of trace elements required by
plants, including zinc.
Pollution outputs are summarized in terms of air emission, wastewater, and
residual wastes.
Air Emissions
Synthetic Ammonia
Air pollutants from the manufacture of synthetic anhydrous ammonia are
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emitted primarily from four process steps:
• regeneration of the desulfurization bed,
• heating of the catalytic steam,
• regeneration of carbon dioxide scrubbing solution,
• steam stripping of process condensate.
More than 95 percent of the ammonia plants in the United States use
activated carbon fortified with metallic oxide additives for feedstock
desulfurization. Vented regeneration steam contains sulfur oxides (SOX) and
hydrogen sulfide (H2S), depending on the amount of oxygen in the steam.
Regeneration may also emit hydrocarbons and carbon monoxide (CO). The
reformer, heated with natural gas or fuel oil, may emit combustion products
such as NOX, CO, SOX, hydrocarbons, and particulates (USEPA, 1993a).
Carbon dioxide (CO2) is removed from the synthesis gas by scrubbing with
monoethanolamine (C2H4NH2OH) or hot potassium carbonate solution.
Regeneration of this CO2 scrubbing solution with steam produces emissions
of water, NH3, CO, CO2 and monoethanolamine (USEPA, 1993a).
Cooling the synthesis gas after low temperature shift conversion forms a
condensate containing NH3, CO2, methanol (CH3OH), and trace metals.
Condensate steam strippers are used to remove NH3 and methanol from the
water, and steam from this may be vented to the atmosphere, emitting NH3,
CO2, and methanol (USEPA, 1993a).
Nitric Acid
Emissions from nitric acid manufacturing consist primarily of NO and NO2
(which account for visible emissions), and trace amounts of HNO3 mist and
NH3. The major source of nitrogen oxides is the tail gas from the acid
absorption tower. In general, the quantity of nitrogen oxides (NOX) emissions
is directly related to the kinetics of the nitric acid formation reaction and
absorption tower design. NOX emissions can increase when there is:
• insufficient air supply to the oxidizer and absorber,
• low pressure, especially in the absorber,
• high temperatures in the cooler/condenser and absorber,
• production of an excessively high-strength product acid,
• operation at high throughput rates,
• faulty equipment such as compressors or pumps which lead to
lower pressures, leaks, and reduced plant efficiency (USEPA,
1993a).
Comparatively small amounts of nitrogen oxides are also lost from acid
concentrating plants. These losses (mostly NO2) are from the condenser
system, but the emissions are small enough to be controlled easily by
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absorbers.
Acid mist emissions do not occur from the tail gas of a properly operated
plant. The small amounts that may be present in the absorber exit gas streams
are typically removed by a separator or collector prior to entering the catalytic
reduction unit or expander.
The acid production system and storage tanks can be a significant source of
visible NOx emissions at nitric acid plants. Emissions from acid storage tanks
are most likely to occur during tank filling (USEPA, 1993a).
Ammonium Nitrate
The primary air emissions from ammonium nitrate production plants are
particulate matter (ammonium nitrate and coating materials), ammonia and
nitric acid. Ammonia and nitric acid are emitted primarily from solution
formation and granulators. Particulate matter (largely as ammonium nitrate)
can be emitted from most of the process operations (USEPA, 1993a).
The emission sources in solution formation and concentration processes are
neutralizers and evaporators, emitting nitric acid and ammonia. The vapor
stream off the top of the neutralization reactor is primarily steam with some
ammonia and NH4NO3 particulates present. Specific plant operating
characteristics, however, make these emissions vary depending upon use of
excess ammonia or acid in the neutralizer. Particulate emissions from these
operations tend to be smaller in size than those from solids production and
handling processes and generally are recycled back to the process (USEPA,
1993a).
Emissions from solids formation processes are ammonium nitrate particulate
matter and ammonia. The sources of primary importance are prill towers (for
high density and low density prills) and granulators (rotary drum and pan).
Emissions from prill towers result from carryover of fine particles and fume
by the prill cooling air flowing through the tower. These fine particles are
from microprill formation, attrition of prills colliding with the tower or one
another, and rapid transition of the ammonia nitrate between crystal states
(USEPA, 1993a).
Microprill formation resulting from partially plugged orifices of melt spray
devices can increase fine dust loading and emissions. Certain designs
(spinning buckets) and practices (vibration of spray plates) help reduce
plugged orifices and thus microprill formation. High ambient air temperatures
can cause increased emissions because of entrainment as a result of higher air
flow required to cool prills and because of increased fume formation at the
higher temperatures (USEPA, 1993a).
Emissions from screening operations are generated by the attrition of the
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ammonium nitrate solids against the screens and against one another. Almost
all screening operations used in the ammonium nitrate manufacturing
industry are enclosed or have a cover over the uppermost screen. Emissions
are ducted from the process for recovery or reuse (USEPA, 1993a).
Bagging and bulk loading operations are also a source of particulate
emissions. Dust is emitted from each type of bagging process during final
filling when dust laden air is displaced from the bag by the ammonium
nitrate. The potential for emissions during bagging is greater for coated than
for uncoated material. It is expected that emissions from bagging operations
are primarily the kaolin, talc or diatomaceous earth coating matter. About 90
percent of solid ammonium nitrate produced domestically is bulk loaded.
While particulate emissions from bulk loading are not generally controlled,
visible emissions are within typical state regulatory requirements (below 20
percent opacity) (USEPA, 1993a).
Urea
Emissions from urea manufacture are mainly ammonia and particulate matter.
Formaldehyde and methanol, hazardous air pollutants, may be emitted if
additives are used. Formalin™, used as a formaldehyde additive, may contain
up to 15 percent methanol. Ammonia is emitted during the solution synthesis
and solids production processes. Particulate matter is emitted during all urea
processes (USEPA, 1993a).
In the synthesis process, some emission control is inherent in the recycle
process where carbamate gases and/or liquids are recovered and recycled.
Typical emission sources from the solution synthesis process are
noncondensable vent streams from ammonium carbamate decomposers and
separators. Emissions from synthesis processes are generally combined with
emissions from the solution concentration process and are vented through a
common stack. Combined particulate emissions from urea synthesis and
concentration operations are small compared to particulate emissions from
a typical solids-producing urea plant. The synthesis and concentration
operations are usually uncontrolled except for recycle provisions to recover
ammonia (USEPA, 1993a).
Uncontrolled emission rates from prill towers may be affected by the
following factors:
• product grade being produced
• air flow rate through the tower
• type of tower bed
• ambient temperature and humidity (USEPA, 1993 a)
The total of mass emissions per unit is usually lower for feed grade prill
production than for agricultural grade prills, due to lower airflows.
Uncontrolled particulate emission rates for fluidized bed prill towers are
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higher than those for nonfluidized bed prill towers making agricultural grade
prills, and are approximately equal to those for nonfiuidized bed feed grade
prills (USEPA, 1993a).
Ambient air conditions can affect prill tower emissions. Available data
indicate that colder temperatures promote the formation of smaller particles
in the prill tower exhaust. Since smaller particles are more difficult to
remove, the efficiency of prill tower control devices tends to decrease with
ambient temperatures. This can lead to higher emission levels for prill towers
operated during cold weather. Ambient humidity can also affect prill tower
emissions. Air flow rates must be increased with high humidity, and higher
air flow rates usually cause higher emissions (USEPA, 1993 a).
In the solids screening process, dust is generated by abrasion of urea particles
and the vibration of the screening mechanisms. Therefore, almost all
screening operations used in the urea manufacturing industry are enclosed or
are covered over the uppermost screen. Emissions attributable to coating
include entrained clay dust from loading, inplant transfer, and leaks from the
seals of the coater (USEPA, 1993a).
Phosphoric Acid
Gaseous fluorides such as silicon tetrafluoride (SiF4) and hydrogen fluoride
(HF) can be major emissions from wet process acid production. Phosphate
rock contains 3.5 to 4.0 percent fluorine. Part of the fluorine from the rock is
precipitated with the gypsum, another part is leached out with the phosphoric
acid product, and the remaining portion is vaporized in the reactor or
evaporator. The relative quantities of fluorides in the filter acid and gypsum
depend on the type of rock and the operating conditions. Final disposition of
the volatilized fluoride depends on the design and operation of the plant
(USEPA, 1993a).
The reactor in which phosphate rock is reacted with sulfuric acid is the main
source of emissions. Fluoride emissions accompany the air used to cool the
reactor slurry. Vacuum flash cooling has replaced the air cooling method to
a large extent, since emissions are minimized in the closed system.
Acid concentration by evaporation is another source of fluoride emissions.
Approximately 20 to 40 percent of the fluorine originally present in the rock
vaporizes in this operation. Particulate matter containing fluorides can be
emitted directly from process equipment. About three to six percent of the
particulates can be fluorides, as measured at one facility (USEPA, 1993a).
Ammonium Phosphates
The major sources of air emissions from the production of ammonium
phosphatic fertilizers include the reactor, the ammoniator-granulator, the
dryer and cooler, product sizing and material transfer, and the gypsum pond.
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The reactor and ammoniator-granulator, produce emissions of gaseous
ammonia, gaseous fluorides such as hydrogen fluoride (HF) and silicon
tetrafluoride (SiF4), and particulate ammonium phosphates. These two
exhaust streams are generally combined and passed through primary and
secondary scrubbers (USEPA, 1993a).
Exhaust gases from the dryer and cooler also contain ammonia, fluorides and
particulates, and these streams are commonly combined and passed through
cyclones and primary and secondary scrubbers. Particulate emissions and low
levels of ammonia and fluorides from product sizing and material transfer
operations are controlled the same way (USEPA, 1993a).
Normal Superphosphates
Sources of emissions at a normal superphosphate plant include rock
unloading and feeding, mixing operations (in the reactor), storage (in the
curing building), and fertilizer handling operations. Rock unloading, handling
and feeding generate particulate emissions of phosphate rock dust. The mixer,
den and curing building emit gases in the form of silicon tetrafluoride (SiF4),
hydrogen fluoride (F£F) and particulates composed of fluoride and phosphate
material (USEPA, 1993a).
Triple Superphosphates
Emissions of fluorine compounds and dust particles occur during the
production of granulated triple superphosphate. Silicon tetrafluoride (SiF4)
and hydrogen fluoride (HF) are released by the acidulation reaction and they
evolve from the reactors, den, granulator, and dryer. Evolution of fluoride is
essentially finished in the dryer and there is little fluoride evolved from the
storage pile in the curing building (USEPA, 1993a).
Sources of particulate emissions include the reactor, granulator, dryer,
screens, cooler, mills, and transfer conveyors. Additional emissions of
particulate result from the unloading, grinding, storage, and transfer of
ground phosphate rock. Facilities may also use limestone, which is received
in granulated form and does not require additional milling (USEPA, 1993a).
Wastewater
Wastewater from the fertilizer industry can be classified into four groups:
process effluents resulting from contact with gas, liquids, or
solids
dedicated effluents which may be separated for use in one
process or for recycling at a controlled rate
effluents from general services such as cleaning or pretreatment
occasional effluents such as leaks or spills
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A number of process wastewater streams from the nitrogenous fertilizer
industry have been identified. Frequently these wastewaters contain high
levels of nitrogenous compounds such as ammonia, nitrates, and organic
nitrogen. In ammonia production, wastewater is generated from process
condensate stripping. Ammonium nitrate manufacturing produces process
wastewater in the neutralization process, the evaporation unit, and air cooling
equipment. The vacuum condenser in urea plants is a source of wastewater.
Most scrubbing operations are also a source of wastewater. Nitric acid
production generates relatively little wastewater since there is no process
wastewater source. Steam generated in nitrogenous fertilizer processing may
contain dissolved and suspended solids, alkalinity, and hardness (USEPA,
1974).
The most common methods for removing nitrogenous compounds include:
• Biological nitrification/denitrification
• Air or steam stripping
• Ion exchange
• Breakpoint chlorination (Water Environment Federation,
1994).
The major source of wastewater from any phosphatic fertilizer manufacturing
process is referred to as "pond water." Phosphoric acid production creates
large quantities of pond water for cooling of the process, concentration of the
product and for processing and storage of the gypsum byproduct. Gypsum
slurry water is decanted from the top of the gypsum stacks and sent to the
cooling pond through collection ditches (USEPA, 1993a). Through
evaporation and recycling, contaminant concentrations in pond water can
reach several grams per liter of phosphates and fluoride. Additional
elemental contaminants in pond water which originate in phosphate rock are
arsenic, cadmium, uranium, vanadium, and radium (USEPA, 1974).
The most common industry treatment for removing phosphorous is lime
neutralization and settling.
Occasional wastewater is generated in any fertilizer production facility by
leaks, spills, cleaning, maintenance, and laboratory tests. Cleaning of cooling
and pollution control systems also produces process wastewater. Cooling
water may contain ammonia, sulfate, chloride, phosphate, chromate, and
dissolved solids which become concentrated through evaporation (USEPA,
1974). The laundry of workers' clothing is another source of wastewater
originating outside the actual process.
Solid/Hazardous/Residual Wastes
One of the largest solid wastes in the fertilizer industry is phosphogypsum
which is produced during phosphoric acid production. Approximately 1.5
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tons of phosphogypsum is produced per ton of phosphate rock fed, or 5 tons
per ton of phosphoric acid produced (expressed as P2O5). Gypsum (calcium
sulphate dihydrate) is a mineral which also occurs in nature. Phosphogypsum
is produced by the reaction of phosphate rock with sulphuric acid during the
process of producing phosphoric acid. The term "phosphogypsum" is used
to specify the particular gypsum arising from the acidulation of phosphate
rock, because it contains trace amounts of many of the mineral impurities that
accompany phosphate rock. One of these impurities is radium, the parent of
radon. Other trace impurities found in phosphogypsum include arsenic,
nickel, cadmium, lead, aluminum, fluoride, and phosphoric acid. Mainly
because of the radium content, the EPA restricts use of phosphogypsum and
stipulates that no phosphogypsum with radium over ten pCi/g can be
removed from the stacks adjacent to the agricultural chemical plants (UNEP,
1996).
The use of waste phosphogypsum for other purposes has been widely
encouraged, but economic and/or quality problems and/or the demand for the
resulting products frequently inhibit or prevent this. These problems relate
not only to the impurities in the gypsum, but also to its relatively high
moisture content. Plasterboard, plaster, and cement are the main possibilities.
It is also possible to recycle phosphogypsum in sulphuric acid production.
The ready availability of natural gypsum and the high cost of gypsum-based
sulphuric acid, as well as the presence of trace contaminants, are the main
obstacles to its use (Miller, 1995). However, in countries where gypsum and
other sulphurous raw materials are scarce, phosphogypsum has been
successfully used for these purposes (UNEP, 1996).
Dumping gypsum on land is not possible everywhere because the material
settles and dries slowly and requires an adequate land area and certain
climatic and soil conditions where the stack is situated. Gypsum stacks are
being increasingly regulated in terms of lining and cap systems to prevent
contaminated leaching or runoff (UNEP, 1996).
All phosphate ores contain traces of radioactive elements and a number of
metals. During processing, these are partitioned between beneficiation
process wastes, the waste from the further processing into intermediate and
finished fertilizer production, and some end up in the final product (UNEP,
1996).
Cadmium is a heavy metal which accumulates in living systems and can
become toxic above certain limits. The quantity of cadmium contained in a
phosphatic fertilizer depends on the source of the rock or waste material from
which it was made. The cadmium content of phosphate rocks varies from
almost zero to over 300 mg/kg P2O5. The acidulation of phosphate rock
partitions the cadmium between the fertilizer product and the by-products,
mainly the phosphogypsum arising from phosphoric acid production (UNEP,
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1996).
The fertilizer industry has for some decades tried to develop cadmium
separation processes. Processes studied so far have shown serious limitations
and problems, with regard to safety, cost, energy consumption or
environmental concerns. Currently available processes are expensive and are
not economically viable except for phosphates destined for human or animal
consumption, which have a greater added value. A process developed for
removing cadmium from phosphoric acid, which is used in the production of
many phosphatic fertilizers (except normal superphosphate), has shown
promise on a laboratory scale, but needs further testing before being used on
an industrial scale (UNEP, 1996).
Off-specification product, spills, and dusts collected in emission control
systems are potential sources of residual wastes. Products are occasionally
suspended or canceled, leaving stockpiles of residual product. Other possible
sources of solid wastes are spent catalysts, spent containers, wastewater
treatment sludges, and spent filters. Many of these wastes are transported off-
site for disposal. However, with good housekeeping techniques and
dedicated systems, some of these wastes may be recycled back into the
process instead of being wasted.
Catalysts used in the steam reforming process need to be replaced every two
to six years. Spent catalysts contain oxides of hexavalent chromium, zinc,
iron, and nickel. They are typically returned to the manufacturer or other
metal recovery companies for recycling and reclamation of valuable materials
(UNEP, 1996).
III.E.2. Pesticide Formulating, Packaging, and Repackaging
As listed below, input raw materials include the pesticide concentrates from
pesticide manufacturing plants as well as diluents and other chemical
additives used in the formulating process:
• Active Ingredients
Organic/inorganic pesticides: insecticides, herbicides, fungicides, and
others. (See Table 10.)
• Formulation and preparation materials
Dry formulations:
organic flours, sulfur, silicon oxide, lime, gypsum, talc,
pyrophyllite, bentonites, kaolins, attapulgite, and volcanic ash.
Liquid formulations:
Solvents: xylenes, kerosenes, methyl isobutyl ketone, amyl
acetate, and chlorinated solvents.
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Propellants: carbon dioxide and nitrogen.
Others: wetting and dispersing agents, masking agents,
deodorants, and emulsifiers (USEPA, 1990).
In addition to pesticide materials, some facilities listed under SIC code 2879
produce fertilizer/pesticide blends. A variety of nitrogenous, phosphatic, and
mixed fertilizers may be inputted into bulk blending tanks to produce these
combinations.
Table 10: Approximate Quantities of Most Commonly Used Conventional
Pesticides in United States Agricultural Crop Production
Chemical
Atrazine
Metolachlor
Metam Sodium
Methyl Bromide
Dichloropropene
2,4-D
Glyphosate
Cyanazine
Pendimethalin
Trifluralin
Acetochlor
Alachlor
EPTC
1995 Consumption
(Million pounds
active ingredient)
68-73
59-64
449-54
39-46
38-43
31-36
25-30
24-29
23-28
23-28
22-27
19-24
9-13
Chemical
Chlorpyrifos
Chlorothalonil
Copper Hydroxide
Propanil
Dicamba
Terbufos
Mancozeb
Fluometuron
MSMA
Bentazone
Parathion
Sodium Chlorate
1995 Consumption
(Million pounds
active ingredient)
9-13
8-12
7-11
6-10
6-10
6-9
6-9
5-9
4-8
4-8
4-7
4-6
Source: Pesticide Industry Sales and Usage, 1994 and 1995 Market Estimates, EPA, August 1997.
Air Emissions
Air emissions can be generated throughout the pesticide formulating and
packaging processes, mostly when fine particulates of pesticide dust become
suspended in air while the materials are being moved, processed, or stored.
Most dust or granule blending mills are equipped with vacuum systems,
cyclones, and wet scrubbers to collect fugitive dust. Some vacuum systems
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are dedicated to certain processes to facilitate reuse of the dust. Other systems
are used to collect dust from a number of areas (USEPA, 1990). Dust
generated by pesticide formulation processes contain AIs which may be toxic
to humans and the environment. Thus, they are important to contain.
Volatile organic compound (VOC) emissions such as xylene may also arise
when solvent-based liquid formulations are produced. VOC emissions may
also be generated during equipment cleaning with solvents.
Wastewater
Process wastewater is defined in 40 CFR 122.2 as "any water which, during
manufacturing or processing, comes into direct contact with or results from
the production or use of any raw material, byproduct, intermediate product,
finished product, or waste product." Wastewater from "the pesticide
formulating industry is typically due to cleaning of equipment and related
process areas and not the actual formulating processes (USEPA, 1996).
Cleaning and decontaminating blending and liquid pesticide mixing and
storage equipment generates pesticide-contaminated wastewater or solvent,
depending upon whether the equipment is used to formulate water or solvent-
based pesticides. Decontamination is performed between batches of different
types of formulations to prevent cross contamination of the subsequent batch.
Decontamination is also performed prior to taking the equipment out of
service for maintenance. The decontamination is commonly performed using
high pressure water hoses equipped with spray nozzles, portable steam
generators, or by running a batch of solvent through the formulating
equipment (USEPA, 1990).
Active ingredient containers, such as 5 5-gallon drums, are often
decontaminated by triple rinsing. The decontamination is usually performed
using a high pressure water hose equipped with a spray nozzle or a portable
steam jenny. " The containers can then be sold or given to commercial
recycling firms, depending on label directions (USEPA, 1990).
Floor, wall, and equipment exterior washing is typically performed using
water hoses equipped with spray nozzles. It may also involve the use of mops
and squeegees. Wastewater is also generated by clean-up of spills and leaks.
Wastewater from these operations typically contains AIs, solvents, and
wetting agents (USEPA, 1990). Other sources of wastewater include:
• Pollution control scrubber water
• Department of Transportation leak test water
• Safety equipment wash water
• Laboratory equipment wash water
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• Shower water
• Laundry water
• Fire protection test water
• Contaminated precipitation runoff (USEPA, 1996)
Solid/Hazardous/Residual Wastes
Residual wastes include containers and container liners potentially
contaminated with pesticides, as well as off-spec product, dust collected from
emission control equipment, and product spills. Contaminated laboratory
equipment and protective workers clothing are other potential solid waste
sources (USEPA, 1990).
Decontamination of the solid-based pesticide blending mills may generate
solid diluent contaminated with pesticides. The diluent typically consists of
clay for dust mills and sand for granule mills (USEPA, 1990).
In case of pesticide products which have been suspended or canceled, there
may be existing stocks of these products remaining. EPA may allow the use
of existing stocks or prohibit such use. State environmental agencies
occasionally collect unusable pesticides.
Procedures for pesticide management have been proposed by EPA, as
authorized under section 19 of the Federal Insecticide, Fungicide, and
Rodenticide Act (FIFRA). For more details, refer to section VI.C on pending
and proposed regulatory requirements.
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Table 11: Summary of Potential Pollution Outputs for the Agricultural
Chemical Industry
Process
Nitric Acid
Absorption Tower
Solution
Formulation and
Granulation
Solids Formation
Regeneration of
Desulfurization
and Filter Beds
Screening
Wet Process
Phosphoric Acid
Production
Unloading of
materials into
blending tanks
Open processing
and storage
equipment
Equipment and
facility cleaning
Laboratory
procedures
Spills and runoff
Pollution control
systems
Air Emissions
NO, NO2, HNO3 in
tailgas
NH3, HNO3
particulates
Particulates, NOX,
SiF4, HF
Hydrocarbons, CO,
NH3, C02
Dust
SiF4, HF
Dust/particulates
released in transfer
VOC's
NA
VOC's and dusts
released
Dust/particulates
released by spill
NA
Process Wastewater
NA
Condensed steam with
NH4NO3andNH3
NA
Condensed steam, NH3,
CO2
NA
Pond water
NA
NA
Washwater, waste
solvent
Washwater, lab testing
water
Contaminated
rainfall/runoff
Contaminated scrubber
water
Residual Waste
Spent tower
materials, trays
NA
Dusts
Spent bed material
Mixed undersized
captured dusts, used
screens
Gypsum
Leftover raw material
containers
NA
Waste sands and
clays, used mops/
squeegees/etc.
Off-spec product used
for testing/analysis
Contaminated solid
product
Spent filter material
Source: Guide to Pollution Prevention, The Pesticide Formulating Industry, Center for
Environmental Research Information, United States EPA, Washington D.C., 1990.
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III.F. Management of Chemicals in Wastestream
Fertilizers
The Pollution Prevention Act of 1990 (PPA) requires facilities to report
information about the management of Toxic Release Inventory (TRI)
chemicals in waste and efforts made to eliminate or reduce those quantities.
These data have been collected annually in section 8 of the TRI reporting
Form R beginning with the 1991 reporting year. The data summarized below
cover the years 1995-1998 and are meant to provide a basic understanding of
the quantities of waste handled by the industry, the methods typically used to
manage this waste, and recent trends in these methods. TRI waste
management data can be used to assess trends in source reduction within
individual industries and facilities, and for specific TRI chemicals. This
information could then be used as a tool in identifying opportunities for
pollution prevention or compliance assistance activities.
While the quantities reported for 1995 and 1996 are estimates of quantities
already managed, the quantities listed by facilities for 1997 and 1998 are
projections only. The PPA requires these projections to encourage facilities
to consider future source reduction, not to establish any mandatory limits.
Future-year estimates are not commitments that facilities reporting under TRI
are required to meet.
Table 12 shows that the TRI reporting fertilizer manufacturing and mixing
facilities managed about 566 million pounds of production related wastes
(total quantity of TRI chemicals in the waste from routine production
operations in column B) in 1996. From the yearly data presented in column
B, the total quantity of production related TRI wastes decreased between
1995 and 1996. Production related wastes are projected to increase in 1997
and 1998. Note that the affects of production increases and decreases on the
quantities of wastes generated are not evaluated here.
In 1996, about 84 percent of the industry's TRI wastes were managed on-site
through recycling, energy recovery, or treatment as shown in columns C, D,
and E, respectively. Most of these on-site managed wastes were recycled on-
site. There is a negligible amount (<1%) of wastes being transferred off-site
for recycling, energy recovery, or treatment. The remaining portion of the
production related wastes (12percentin 1995 and 16 percent in 1996), shown
in column I, is either released to the environment through direct discharges
to air, land, water, and underground injection, or is transferred off-site for
disposal.
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Table 12: Source Reduction and Recycling Activity for the Fertilizer Industry as
Reported within TRI
A
Year
1995
1996
1997
1998
B
Quantity of
Production-
Related
Waste
(106lbs.)a
719
566
606
617
On-Site
C
%
Recycled
76%
77%
77%
78%
D
% Energy
Recovery
8%
1%
1%
1%
E
% Treated
4%
6%
7%
7%
Off-Site
F
%
Recycled
0%
0%
0%
0%
G
% Energy
Recovery
0%
0%
0%
0%
H
% Treated
0%
0%
0%
0%
I
% Released and
Disposed0 Off-
site
12%
16%
15%
14%
Source: 1996 Toxics Release Inventory Database.
a Within this industry sector, non-production related waste < 1% of production related wastes for 1996.
Total TRI transfers and releases as reported in section 5 and 6 of Form R as a percentage of production related
wastes.
Percentage of production related waste released to the environment and transferred off-site for disposal.
Pesticides and Miscellaneous Agricultural Chemicals
Table 13 shows that the TRI reporting pesticide and miscellaneous
agricultural chemicals facilities managed about 252 million pounds of
production related wastes (total quantity of TRI chemicals in the waste from
routine production operations in column B) in 1996. From the yearly data
presented in column B, the total quantity of production related TRI wastes
increased between 1995 and 1996. Production related wastes were projected
to continue to increase in 1997 and 1998. Note that the affects of production
increases and decreases on the quantities of wastes generated are not
evaluated here.
In 1996, about 95 percent of the industry's TRI wastes were managed on-site
through recycling, energy recovery, or treatment as shown in columns C, D,
and E, respectively. Most of these on-site managed wastes were recycled on-
site. A small portion of the remaining wastes (4% in 1996) are transferred
off-site for recycling, energy recovery, or treatment. The remaining one
percent of the production related wastes, shown in column I, is either released
to the environment through direct discharges to air, land, water, and
underground injection, or is transferred off-site for disposal.
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Table 13: Source Reduction and Recycling Activity for the Pesticide and
Miscellaneous Agricultural Chemicals Industry as Reported within TRI
A
Year
1995
1996
1997
1998
B
Quantity of
Production-
Related
Waste
(106 lbs.)a
245
252
266
279
On-Site
C
%
Recycled
85%
84%
84%
85%
D
% Energy
Recovery
0%
0%
0%
0%
E
%
Treated
10%
11%
11%
11%
Off-Site
F
% Recycled
2%
2%
1%
1%
G
% Energy
Recovery
1%
1%
1%
1%
H
% Treated
1%
1%
2%
1%
I
% Released and
Disposed0 Off-
site
2%
1%
1%
1%
Source: 1996 Toxics Release Inventory Database.
a Within this industry sector, non-production related waste < 1% of production related wastes for 1996.
b Total TRI transfers and releases as reported in section 5 and 6 of Form R as a percentage of production related
wastes.
0 Percentage of production related waste released to the environment and transferred off-site for disposal.
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IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the pollutant
releases that are reported by this industry in correlation with other industries.
The best source of comparative pollutant release information is the Toxic
Release Inventory (TRI). Pursuant to the Emergency Planning and
Community Right-to-Know Act, TRI includes self-reported facility release
and transfer data for over 600 toxic chemicals. Facilities within SIC Codes
20 through 39 (manufacturing industries) that have more than 10 employees,
and that are above weight-based reporting thresholds are required to report
TRI on-site releases and off-site transfers. The information presented within
the sector notebooks is derived from the most recently available (1996) TRI
reporting year (which includes over 600 chemicals), and focuses primarily on
the on-site releases reported by each sector. Because TRI requires consistent
reporting regardless of sector, it is an excellent tool for drawing comparisons
across industries. TRI data provide the type, amount and media receptor of
each chemical released or transferred.
Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general, toxic
chemical releases have been declining. In fact, according to the 1996 Toxic
Release Inventory Public Data Release, reported onsite releases of toxic
chemicals to the environment decreased by 5 percent (111.6 million pounds)
between 1995 and 1996 (not including chemicals added and removed from
the TRI chemical list during this period). Reported releases dropped by 48
percent between 1988 and 1996. Reported transfers of TRI chemicals to off-
site locations increased by 5 percent (14.3 million pounds) between 1995 and
1996. More detailed information can be obtained from EPA's annual Toxics
Release Inventory Public Data Release book (which is available through the
EPCRA Hotline at 800-535-0202), or directly from the Toxic Release
Inventory System database (for user support call 202-260-1531).
Wherever possible, the sector notebooks present TRI data as the primary
indicator of chemical release within each industrial category. TRI data
provide the type, amount and media receptor of each chemical released or
transferred. When other sources of pollutant release data have been obtained,
these data have been included to augment the TRI information.
TRI Data Limitations
Certain limitations exist regarding TRI data. Within some sectors, (e.g. dry
cleaning, printing and transportation equipment cleaning) the majority of
facilities are not subject to TRI reporting because they are not considered
manufacturing industries, or because they are below TRI reporting thresholds.
For these sectors, release information from other sources has been included.
In addition, many facilities report TRI more under than one SIC code
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reflecting the multiple operations carried out onsite whether or not the
operation is the facilities primary area of business as reported to the U.S.
Census Bureau. Reported chemicals are limited to the approximately 600
TRI chemicals. A portion of the emissions from agricultural chemical
facilities, therefore, are not captured by TRI. Also, reported releases and
transfers may or may not all be associated with the industrial operations
described in this notebook.
The reader should also be aware that TRI "pounds released" data presented
within the notebooks is not equivalent to a "risk" ranking for each industry.
Weighting each pound of release equally does not factor in the relative
toxicity of each chemical that is released. The Agency is in the process of
developing an approach to assign toxicological weightings to each chemical
released so that one can differentiate between pollutants with significant
differences in toxicity. As a preliminary indicator of the environmental
impact of the industry's most commonly released chemicals, the notebook
briefly summarizes the toxicological properties of the top five chemicals (by
weight) reported by each industry.
Definitions Associated With Section IV Data Tables
General Definitions
SIC Code -- is the Standard Industrial Classification (SIC) code, a statistical
classification standard used for all establishment-based federal economic
statistics. The SIC codes facilitate comparisons between facility and industry
data.
TRI Facilities — are manufacturing facilities that have 10 or more full-time
employees and are above established chemical throughput thresholds.
Manufacturing facilities are defined as facilities in Standard Industrial
Classification primary codes 20-39. Facilities must submit estimates for all
chemicals that are on the EPA's defined list and are above throughput
thresholds.
Data Table Column Heading Definitions
The following definitions are based upon standard definitions developed by
EPA's Toxic Release Inventory Program. The categories below represent the
possible pollutant destinations that can be reported.
RELEASES — are on-site discharges of atoxic chemical to the environment.
This includes emissions to the air, discharges to bodies of water, releases at
the facility to land, as well as contained disposal into underground injection
wells.
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Releases to Air (Point and Fugitive Air Emissions) — include all air
emissions from industry activity. Point emissions occur through confined air
streams as found in stacks, vents, ducts, or pipes. Fugitive emissions include
equipment leaks, evaporative losses from surface impoundments and spills,
and releases from building ventilation systems.
Releases to Water (Surface Water Discharges) — encompass any releases
going directly to streams, rivers, lakes, oceans, or other bodies of water.
Releases due to runoff, including storm water runoff, are also reportable to
TRI.
Releases to Land -- occur within the boundaries of the reporting facility.
Releases to land include disposal of toxic chemicals in landfills, land
treatment/application farming, surface impoundments, and other disposal on
land (such as spills, leaks, or waste piles).
i
Underground Injection -- is a contained release of a fluid into a subsurface
well for the purpose of waste disposal. Wastes containing TRI chemicals are
injected into either Class I wells or Class V wells. Class I wells are used to
inject liquid hazardous wastes or, dispose of industrial and municipal
wastewaters beneath the lowermost underground source of drinking water.
Class V wells are generally used to inject non-hazardous fluid into or above
an underground source of drinking water. TRI reporting does not currently
distinguish between these two types of wells, although there are important
differences in environmental impact between these two methods of injection.
TRANSFERS — are transfers of toxic chemicals in wastes to a facility that
is geographically or physically separate from the facility reporting under TRI.
Chemicals reported to TRI as transferred are sent to off-site facilities for the
purpose of recycling, energy recovery, treatment, or disposal. The quantities
reported represent a movement of the chemical away from the reporting
facility. Except for off-site transfers for disposal, the reported quantities do
not necessarily represent entry of the chemical into the environment.
Transfers to POTWs — are wastewater transferred through pipes or sewers
to a publicly owned treatments works (POTW). Treatment or removal of a
chemical from the wastewater depends on the nature of the chemical, as well
as the treatment methods present at the POTW. Not all TRI chemicals can
be treated or removed by a POTW. Some chemicals, such as metals, may be
removed but not destroyed and may be disposed of in landfills or discharged
to receiving waters.
Transfers to Recycling — are wastes sent off-site for the purposes of
regenerating or recovery by a variety of recycling methods, including solvent
recovery, metals recovery, and acid regeneration. Once these chemicals have
been recycled, they may be returned to the originating facility or sold
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commercially.
Transfers to Energy Recovery ~ are wastes combusted off-site in industrial
furnaces for energy recovery. Treatment of a chemical by incineration is not
considered to be energy recovery.
Transfers to Treatment ~ are wastes moved off-site to be treated through
a variety of methods, including neutralization, incineration, biological
destruction, or physical separation. In some cases, the chemicals are not
destroyed but prepared for further-waste management.
Transfers to Disposal -- are wastes taken to another facility for disposal,
generally as a release to land or as an injection underground.
IV.A. EPA Toxic Release Inventory for the Fertilizer, Pesticide, and Agricultural Chemical
Industry
This section summarizes the TRI data of fertilizer manufacturing and mixing
facilities reporting SIC codes 2873,2874, or 2875 as their primary SIC code
and of pesticide and miscellaneous agricultural chemicals formulating
facilities reporting SIC code 2879 as their primary SIC code.
According to the 1995 Toxics Release Inventory (TRI) data, 190 fertilizer and
pesticide facilities reporting SIC 2873,2874, 2875, or 2879 released (to the
air, water, or land) and transferred (shipped off-site or discharged to sewers)
a total of 106 million pounds of toxic chemicals during calendar year 1996.
This represents approximately 2 percent of the 5.6 billion pounds of releases
and transfers from all manufacturers (SICs 20-39) reporting to TRI that year.
The top two chemicals released by weight are ammonia and phosphoric acid
(both from fertilizer manufacturing). These two account for about 89 percent
(82 million pounds) of the industry's total releases. Xylene, methanol, and
ethylbenzene are the three top chemicals transferred by weight (all from
pesticide formulating). These three account for about 71 percent (9 million
pounds) of the total TRI chemicals transferred by the industries. The
variability in facilities' TRI chemical profiles may be attributed to the variety
of processes and products in the industries. Eighty-seven percent of the 243
different chemicals reported were reported by fewer than 10 facilities.
Fertilizers (SIC 2873,2874,2875)
According to 1996 TRI data, fertilizer manufacturing and mixing facilities
released and transferred approximately 93 million pounds of pollutants
during calendar year 1996. One hundred and ninety facilities reported TRI
emissions for 46 chemicals. Only 13 of the 46 chemicals (28 percent) were
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reported (as releases and/or transfers) by ten or more facilities, evidence of
the diversity of the industry. Fertilizer facilities released an average of
481,000 pounds per facility and transferred an average of 8,000 pounds per
facility. The high release per facility values are, in a large part, a result of
significant releases for ammonia and phosphoric acid from seventy or more
facilities.
Releases
Transfers
Table 14 presents the number and weights of chemicals released by fertilizer
manufacturing and mixing facilities reporting SIC 2873, 2874, and 2875 in
1996. The total quantity of releases was 91.3 million pounds or 98 percent
of the total weight of chemicals reported to TRI by the fertilizer industry (i.e.,
releases and transfers). The top chemical released by this industry is
ammonia, accounting for 54 percent of the total releases. Phosphoric acid is
the next largest release at 35 percent of the total. Fifty-eight percent of all
TRI releases in the fertilizer industry were air emissions, 53 percent as point
source and 5 percent as fugitive. Ammonia accounts for 91 percent of air
releases. The majority of the other releases were land disposed (32 percent)
with phosphoric acid accounting for 99 percent of land disposals. The
remaining nine percent was released as water discharges or underground
injections.
Table 15 presents the number and weights of chemicals transferred off-site
by fertilizer manufacturing and mixing facilities reporting SIC 2873, 2874,
or 2875 in 1996. The total amount of transfers was about 1.5 million pounds
or only two percent of the total amount of chemicals reported to TRI by the
fertilizer industry (i.e., releases and transfers). Transfers to recycling
facilities accounted for the largest amount, 51 percent of the total transfers.
The next greatest percentage went for disposal and the rest to treatment
facilities. No energy recovery transfers were reported for this industry.
Copper compounds, phosphoric acid, and zinc compounds represented the
largest transfers (primarily to recycling), as 60 percent of the total transfers.
Ammonia only accounted for 4 percent of the transfers compared to 54
percent of releases.
Pesticides and Miscellaneous Agricultural Chemicals (SIC 2879)
According to 1996 TRI data, pesticide formulating facilities released and
transferred approximately 13 million pounds of pollutants during calendar
year 1996. One hundred and ninety-three facilities reported TRI emissions
for 197 chemicals in 1996. Only 18 (9 percent) of these chemicals were
reported by ten,or more facilities, evidence of the particularly diverse nature
of the industry. Pesticide formulating facilities released an average of 10,000
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pounds of pollutants per facility and transferred an average of 59,000 pounds
per facility. The high average transfer per facility is due mostly to high
average xylene, ethylbenzene, and methariol transfers.
Releases
Transfers
Table 16 presents the number and weights of chemicals released by pesticide
and miscellaneous agricultural chemicals formulating facilities reporting SIC
2879 in 1996.. The total amount of releases was 2.0 million pounds or 15
percent of the total quantity of TRI chemicals reported by the pesticide and
miscellaneous agricultural chemicals industry (i.e., releases and transfers).
This is substantially less than the 98 percent of reported chemicals released
by the fertilizer industry. The top two chemicals released by this industry are
methanol (23 percent of releases) and dichloromethane (13 percent of
releases).
About 69 percent (1.4 million pounds) of all the chemicals released by the
pesticide industry were released to air in the form of point source emissions
(50 percent) and fugitive air releases (19 percent). Air releases were
primarily comprised of dichloromethane, carbon disulfide, and methyl
isobutyl ketone. Approximately 29 percent of the releases were by
underground injection, and the remaining releases were to water (2 percent)
and land disposal (1 percent). The relatively large number of chemicals
reported to TRI under SIC 2879 compared to the fertilizer industry illustrates
the variety of chemical formulations produced by the pesticide industry.
Table 17 presents the number and weights of chemical transfers by the
pesticide and miscellaneous agricultural chemicals formulating facilities
reporting SIC 2879 in 1996. The total amount of transfers off-site was 11.3
million pounds or 85 percent of the total amount of chemicals reported to TRI
by the pesticide industry (i.e., releases and transfers). Xylene, methanol, and
ethylbenzene accounted for 58, 12, and 10 percent, respectively, of the
chemical TRI transfers. Transfers to recycling facilities accounted for the
largest quantity (51 percent) although only eight facilities reported recycling
transfers. Xylene accounted for 84 percent of all recycling transfers. Energy
recovery and treatment accounted for 23 and 31 percent respectively. The
remainder of transfers consisted of off-site disposals.
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Table 14: 1996 TRI Releases for Agricultural Chemicals Facilities (SICs 2873,2874,2875)
by Number of Facilities Reporting (Releases reported in pounds/year)
Chemical Name
Ammonia
Phosphoric Acid
Zinc Compounds
Manganese Compounds
Nitrate Compounds
Copper Compounds
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Nitric Acid
Chlorine
Methanol
Formaldehyde
Chromium Compounds
Nickel Compounds
Copper
Zinc (Fume or Dust)
Lead Compounds
Hydrogen Fluoride
Diethanolamine
2,4-D
Manganese
Diazinon
Benfluralin
Atrazine
Trifluralin
Chromium
Cadmium Compounds
Cobalt Compounds
Diisocyanates
Certain Glycol Ethers
Carbaryl
N-butyl Alcohol
Quintozene
Mecoprop
Methoxone
Ethylene Glycol
Methyl Isoburyl Ketone
Dicofol
2,4-DP
Asbestos (Friable)
Dicamba
Nickel
Vanadium (Fume or Dust)
Hydrochloric Acid (1995 and after
"Acid Aerosols" Only)
Thiophanate-methyl
Pendimethalin
Oxyfluorfen
# Reporting
Chemical
106
72
56
43
42
37
32
30
30
20
13
11
10
8
8
7
7.'
6
5
5
4
4
3
2
2
1
1
1
1
1
1
1
1
- 1
190**
Fugitive
Air
4,590,371
1,452
3,946
5,292
1,529
1,477
3,237
22,388
5,345
38,447
730
251
255
5
5
17
15,325
5
21
5
0
445
140 '
239
400
\
, 10
0
5
5
0
10
5
750
73,325
250
7
0
12
400
0
0
0
0
4,766,111
Point
Air
43,967,432
8,631
2,969
1,696
261,250
525
1,435,613
17,418
25,787
3,068,775
20,874
0
250
10
8
270
13,820
7,907
251
10
2
258
0
0
0
70
0
5
0
0
250
250
0
16,241
0
250
0
250
0
0
-o
0
0
48,851,072
Water I
Discharges
427,065
2,939,394
7,817
1,500
3,108,211
1,443
5
10
7,818
63,362
10
536
795
0
0
510
15
31,470
0
0
0
0
0
0
0
0
0
0
6
0
0
0
13,000
0
0
0
0
0
0
0
0
0
6.603.991
Jnderground
Injection
539,900
0
65
0
971,850
60
15,000
0
0
20
220
90
270
0
0
0
0
0
0
0
Q
0
0
0
0
0
0
0
" 0
0
0
0
0
0
0
0
0
0
0
260,000
0
0
0
1,787,475
Land
Disposal
78,814
29,071,310
4,023
500
125,960
528
25,587
7,655
0
185
5.
1,430
565
0
0
0
3,309
0
0
0
0
0
. 0
0
0
0
0
0
0
0
0
0
250
0
0
0
0
0
0
0
0
0
0
29,320,121
Total
Releases
49,603,582
32,020,787
18,820
8,988
4,468,800
4,033
1,479,442
47,471
38,950
3,170,789
21,839
2,307
2,135
15
13
797
32,469
39,382
272
15
2
703
140
239
400
80
0
10
5
0
260
255
14,000
89,566
250
257
0
262
400
260,000
0
0
0
91.327,740
Avg.
Releases
Per Facility
467,958
444,733
336
209
106,400
109
46,233
1,582
1,298
158,539
1,680
210
214
2
2
114
4,638
6,564
54
3
1
176
47
120
200
80
0
10
5
0
260
255
14,000
89,566
250
257
0
262
400
260,000
0
0
0
480,672
** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
Sector Notebook Project
81
September 2000
-------
Agricultural Chemical Industry
Chemical Releases and Transfers
Table 15: 1996 TRI Transfers for Agricultural Chemicals Facilities (SICs 2873,2874,2875)
by Number and Facilities Reporting (Transfers reported in pounds/year)
Chemical Name
Ammonia
Phosphoric Acid
Zinc Compounds :
Manganese Compounds
Nitrate Compounds
Copper Compounds
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Nitric Acid
Chlorine
Methanol
Formaldehyde
Chromium Compounds
Nickel Compounds
Copper
Zinc (Fume or Dust)
Lead Compounds
Hydrogen Fluoride
Diethanolaminc
2,4-D
Manganese
Diazinon
Bcnfluralin
Atrnzinc
Trifluralin
Chromium
Cadmium Compounds
Cobalt Compounds
Diisocyanatcs
Certain Glycol Ethers
Carbaryl
N-butyl Alcohol
Quintozcnc
Mccoprop
Mcthoxonc
Ethylcnc Glycol
Methyl Isobutyl Kctone
Dicofol
2,4-DP
Asbestos (Friable)
Dicamba
Nickel
Vanadium (Fume or Dust)
Hydrochloric Acid (1995 and after "Acid
Aerosols" Only)
Thiophanatc-mcthyl
Pcndimcthalin
Oxyfluorfcn
#
Reporting
Chemical
106
72
56
43
42
37
32
30
30
20
13
11
10
8
8
7
7
6
5
5
4
4
3
2
2
1
1
1
1
190**
Potw
Transfers
51600
0
5
0
95000
0
0
0
25
1542
250
0
0
0
0
0
0
19940
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
168.362
Disposal
Transfers
289528
1060
1000
11861
250
14207
505
10
250
19300
337,971
Recycling
Transfers
179327
14657
384419
63230
81600
14657
14657
14657
185
14657
782,046
Treatment
Transfers
11477
418
45834
3834 '
750
11000
20000
5
20000
4613
4608
1250
107880
591
4358
250
250
250
250
4358
4358
4358
250,692
Energy
Recovery Total
Transfers Transfers
63077
289946
226226
4834
110407
407280
0
250
25
1542
250
77437
101600
14657
15167
10
0
39940
4613
0
4608
1250
107880
0
14657
0
0
591
0
4358 -
250
250
185
0
250
250
19300
250
14657
0
4358
4358
4358
0 1.539.071
Avg
Transfer
Per
Facility
595
4,027
4,040
112
2,629
11,008
0
8
1
77
19
7,040
10,160
1,832
1,896
1
0
6,657
923
0
1,152
313
35,960
0
7,329
0
0
591
0
4,358
250
250
185
0
250
250
19,300
250
14,657
0
4,358
4,358
4,358
8.100
** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
Sector Notebook Project
82
September 2000
-------
Agricultural Chemical Industry
Chemical Releases and Transfers
Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of Facilities
Reporting (Releases reported in pounds/year)
# Reporting
Chemical Name Chemical
1 ,2,4-trimethy Ibenzene
Xylene (Mixed Isomers)
Ethylene Glycol
Naphthalene
Malathion
Diazinon
Ammonia
2,4-D
Carbaryl
Methanol
N-butyl Alcohol
Captan
Quintozene
Trifluralin
Chlorothalonil
2,4-d 2-ethylhexyl Ester
Ethylbenzene
Atrazine
Copper Compounds
Zinc Compounds
Dimethylamine
Arsenic Compounds
Certain Glycol Ethers
Lindane
Bromomethane
Chloropicrin
Cumene
Permethrin
Dicamba
Piperonyl Butoxide
Dimethoate
Mecoprop
Toluene
Thiram
Methyl Parathion
Diuron
Prometryn
Chlorine
Manganese Compounds
Nitrate Compounds
1 , 1 , 1 -trichloroethane
Carbon Disulfide
Methoxone
Metham Sodium
N-methyl-2-pyrrolidone
Carbofaran
Bromoxynil Octanoate
Maneb
Cyanazine
Formaldehyde
Chloromethane
Dichloromethane
O-xylene
Methyl Isobutyl Ketone
Simazine
Hydrochloric Acid (1995 and after
"Acid Aerosols" Only)
Phosphoric Acid
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Metribuzin
Acephate
Chromium Compounds
Chlorodifluoromethane
Maleic Anhydride
M-xylene
Dicofol
Aldicarb
Linuron
Ethyl Dipropylthiocarbamate
Paraquat Dichloride
24
24
22
21
17
17
14
13
12
12
12
12 •
11
11
11
11
10
10
9
9
9
8
8
8
8
8
8
8
7
6
6
6
6
6
6
6
6
6
5
5
5
5
§
5
5
5
5
5
4
4
4
4
4
4
4
4
4
4
4
3
3
3
3
3
3
3
3
1
Fugitive
Air
5310
24494
7856
4536
571
21
20529
1926
1005
12434
1498
519
1050
1304
622
2160
1065
- 4000
547
2299
3547
267
10501
255
9398
2240
108
976
348
35
' 225
510 .
11676
510
716
261
250
6020
6657
5
1729
6817
265
1266
310
22
270
0
285
3020
7434
12585
5602
105310
1005
3698
438
1009
2
255
250
11406
1079
508
210
21
5
6706
son
Point Water Underground
Air Discharges Injection
3185
16327
819
3402
280
227
36889
1535
9005
. 35850
1668
12106
561
2578
1005
1065
421
2430
188
2307
7560
1089
250
255
63421
5835
78
509
324
6
260
920
27350
1000
312
1250
268
2455
75
6
7400
112994
510
258
10
274
251
0
1625
8018
82165
256135
35250
58755
1005
48257
0
1.
1010
1250
88
2441
2385
250
0
1205
5
619
snn
0
0
2521
17
10
10
4908
5
10
8217
0
5
0
87
0
5
• o
5
11
0
0
14
0
5
0
0
0
0
132
0
10
0
39
0
0
8
0
0
0
22000
0
0
250
1
5
1
0
0
0
1083
0
100
5
5
5
0
0
0
5
0
3
0
5
0
0
0
5
2
0
0
17760
2290
0
0
0
2300
0
0
400300
0
5
0
0
0
0
0
1
0
0
250
0
0
0
0
0
0
0
59200
0
0
0
536
0
0
0
0
5 "
0
0
. 0
5
0
0
750
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
29
0
Land
Disposal
0
0
7922
20
0
0
360
255
2500
51
0
0
0
0
1670
. 0
0
0
5
0
0
0
0
250
0
0
0
0
0
0
0
255
71
0
0
0
0
0
0
0
0
0
250
2
5
0
0
0
0
5 '
9
23
5
5
0
56
0
15
0
0
0
0
0
0
0
5
0
0
n
Avg.
Total Releases
Releases Per Facility
8495
58581
21408
7975
861
258
64986
3721
12520
456852
3166
12635
1611
3969
3297
3230
1486
6436
751
4606
11357
1370
10751
765
72819
8075
186
1485
60004
41
495
1685
39672
1510
1028
1519
518
8480
6732
22011
9129
119816
1275
1527
1080
297
521
0
1910
12126
89608
268843
40862
164075
2015
52011
438
1025
1017
1505
341
13847
3469
758
210
1231
15
7356
LQflD
354
2,441
973
380
51
15
. 4,642
286
1,043
38,071
264
1,053
146
361
300
294
149
644
83
512
1,262
171
1,344
96
9,102
1,009
23
186
8,572
7
83
281
6,612
252
171
253
86
1,413
1,346
4,402
1,826
23,963
255
305
216
59
104
0
382
3,032
22,402
67,211
10,216
41,019
504
13,003
110
256
254
376
114
4,616
1,156
253
70
410
5
2452
™
Sector Notebook Project
83
September 2000
-------
Agricultural Chemical Industry
Chemical Releases and Transfers
Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of Facilities
# Reporting
Chemical Name Chemical
Propachlor
Fluomcturon
Dimcthyltuninc Dicamba
2arboxin
"oppcr
Ethoprop
Tliiophanate-methyl
Pcndimclhalin
ilcxazinonc
Ethylcnebisdithiocarbamic Acid, Salts
and Esters
Trichlorfon
Parathion
Dichlorvos
S,S,s-tributyItrithiophosphate
2,4-db
1,4-dichIorobenzcne
1,2-dichlorocthanc
Chlorobcnzcnc
Phenol
Dicthonolaminc
2,4-dp
Mated
llydrazinc
1,3-dichloropropylcne
Propanil
Amctryn
Cycloatc
Bromoxynil
2,4-d Butoxycthyl Ester
Sodium Dicamba
Dipolassium Endothall
Molinatc
Chlorpyrifos Methyl
Zinc (Fume or Dust)
Nitric Acid
Rcsmcthrin
Dcsmcdipham
Thiophanate Etliyl
Tttiobcncatb
Thiodicarb
Propiconazolc
Cyfluthrin
Femes afen
Quizalofop-cthyl
Lactofcn
Bifcmhrin
Myclobutanil
Antimony Compounds
Chloroplicnols
Cyanide Compounds
Dlisocyanalcs
Lead Compounds
Carbon Tctrachloridc
Formic Acid
Isopropyl Alcohol (Manufacturing,
Strong-acid Process Only, No Supplies)
N.n-dimcthylform amide
Mcthoxychlor
Vinyl Chloride
Tcrt-butyl Alcohol
2-mcthyllactonitrilc
Triphcnyltin Hydroxide
Hcxachlorocyclopentadicne
Dicyclopcntadicnc
Dimethyl Sulfatc
Methyl Ethyl Kctone
Dichloran
P-xylcne
1,3-buIadicnc
nyclnhexnnnl ;
3
3
3
3
3
3
3
3
3
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Fugitive
Air
0
260
580
8
0
250
70
970
17
1057
6
1325
470
340
6300
320
533
255
250
0
201
2301
250
255
0
5
262
5
39
, 315
5
250
4000
1
15
530
250
5
3
255
1
847
6
6
250
15
130
66
810
0
1
5
552
20
0
5
141
32
5
77
0
Point Water Underground
Air Discharges Injection
0
512
5
0
5
615
9
260
283
57
6
473
250
1371
57000
0
0
. 255
5
50
12
120
2627
298
49
10
401
750
4
271
. 5
0
398
0
0
281
1000
5
13
250
0
29
1
2
250
41
139
41000
700
15
38
5
644
121
180
5
562
240
5
1200
18
0
0
0
0
0 .
0
0
22
0
0
6
2
0
0
33
0
1
0
0
0
0
0
0
5
1
0
0
0
0
1
0
5
0
0
6
0
0
0
0
6
0
6
0
5
6
0
29
0
0
0
0
0
0
6
0
6
6 •
0
f>
0
0
0
0
0
0
0
0
0
0
6
0
0
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
6
0
0
0
• 0
0
0
0
6
73400
0
6
5
0
0
0
0
0
0
0
250
0
6
6
0
o
Land
Disposal
0
0
5
0
0
0
0
140
0
0
6
8
0
0
250
0 ~
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
280
0
0
6
250
0 •
350
0
0
- 0
0
0
0
5
6
0
0
0
0
0
0
0
0
6
0
6
6
0
o
Total
Releases
0
772
590
8
5
865
79
1392
300
1114
0
1808
720
1711
63583
320
534
510
260
50
213
2421
2877
558
52
15
663
755
43
587
10
250
4683
1
15
811
1500.
10
366
505
1
876
7
2
73900
66
269
41071
1539
15
39
10
1196
141
180
260
703
272
10
1277
18
Avg.
Releases
Per Facility
0
257
197
3
2
288
26
464
100
557
6
904
360
856
31,792
160
267
255
130
25
107
1,211
1,439
279
26
8
332
378
22
294
5
125
2,342
1
8
406
750
5
183
253
1
438
4
2
73,900
66
269
41,071
1,539
15
39
10
1,196
141
180
260
703
272
10
1,277
1R
Sector Notebook Project
84
September 2000
-------
Agricultural Chemical Industry
Chemical Releases and Transfers
Table 16: 1996 TRI Releases for Agricultural Chemicals Facilities (SIC 2879) by Number of Facilities
Reporting (Releases reported in pounds/year)
# Reporting
Chemical Name Chemical
SJ-hexane
Pyridine
Propoxur
Di(2-ethylhexyl) Phthalate
Hexachlorobenzene
1 ,2,4-trichlorobenzene
2,4-dichlorophenol
Triethylamine
Hydroquinone
Folpet
Mferphos
Oxydemeton Methyl
Bromacil
Methyl Isothiocyanate
Perchloromethyl Mercaptan
Methyl Isocyanate
Pebulate
Benfluralin
Nitrapyrirf
Triallate
Dodine
Dimethyl Chlorothiophosphate
Temephos
Terbacil
Hydrogen Fluoride
Bromine
Mevinphos
•Phosphine
Creosote
Zineb
Fenbutatin Oxide
Alachlor
Benomyl
Oryzalin
Oxydiazon
Aluminum Phosphide
Bendiocarb
Pronamide
Toluene Diisocyanate (Mixed Isomers)
Propetamphos
Amitraz
Tebuthiuron
Diflubenzuron
Sulprofos
Dinocap
Fenpropathrin
Profenofos
Oxyfluorfen
Triadimefon
Vinclozolin
Fenvalerate
Dimethipin
Triclopyr Triethylammonium Salt
Fenarimol
Acifluorfen, Sodium Salt
Chlorsulfuron
Fluvalinate
Chlorimuron Ethyl
Tribenuron Methyl .
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1 .
1
1
•1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
193**
Fugitive
Air
2910
4836
10
5
8000
2630
3298
250
0
200
6
0
0
0
250
250
5
0
6
0
0
0
15
2100
5
5
5
6
i
6
6
0
6
0
369.954
Point Water Underground
Air Discharges Injection
5560
5617
25
0
750
250
101
5
5
0
0
0
510
0
250
250
5
0
0
0
0
1076
25
6
250
250
5
5
6
6
6
1
1
1
995,519
0
0
6
0
0
0
0
0
0
0
6
0
0
0
0
6
0
0
6
0
0
0
0
6
6
6
6
6
6
6
2
39,600
0
0
6
0
750
15390
0
0
0
0
0
0
0
0
6
0
0
6
0
0
0
0
6
6
6
6
6
6
6
6
0
6
0
573.228
Land
Disposal
0
0
6
0
0
0
0
0
0
0
6
0
0
0
0
6
0
0
6
0
0
0 •
0
6
6
6
250
6
6
6
5
0
6
0
15,287
Avg.
Total Releases
Releases Per Facility
8470
10453
35
5
9500
18270
3399
255
5
200
6
0
510
0
500
500
10
0
6
0
0
' 1076
40
2100
255
255
260
5
1
6
7
1
i
i
1.993.588
8,470
10,453
35
5
9,500
18,270
3,399
255
5
200
6
0
510
0
500
500
10
0
6
0
0
1,076
40
2,100
255
255
260
5
1
6
i
i
i
i
10,329
** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
Sector Notebook Project
85
September 2000
-------
Agricultural Chemical Industry
Chemical Releases and Transfers
Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)
by Number and Facilities Reporting (Transfers reported in pounds/year)
Chemical Name
1,2,4-trimcthylbenzcne
Xylcnc (Mixed Isomers)
Gthylcnc Glycol
Naphthalene
Malnthion
Diazinon
Ammonia
2,4-d
Cartjaryl
Vfethanol
M-butyl Alcohol
Captan
Ouintozenc
Trifluralin
Chlorothaloni!
2,4-d 2-cthylhexyl Ester
Elhylbcnzenc
Atrazinc
Copper Compounds
Zinc Compounds
Dimcthylaminc
Arsenic Compounds
Certain Glycol Ethers
Lindanc
Bromomcthanc
Chloropicrin
Cumcnc
Pcrmcthrin
Dicamba
Piperonyl Butoxidc
Dimcthoatc
Mccoprop
Toluene
Tliiram
Methyl Parathion
Diuron
Promctryn
Chlorine
Manganese Compounds
Nitrate Compounds
1,1,1-trichlorocthanc
Carbon Disulfide
Mcthoxone
Mctliam Sodium
N-mcthyl-2-pyrrolidonc
Carbofuran
Qromoxynil Octanoatc
Maneb
Cyanazinc
Formaldehyde
Chloromcthanc
Oichloromctlianc
0-xylcne
Methyl Isobutyl Kctone
Simazinc
Hydrochloric Acid (1995 and after "Acid
Aerosols" Only)
Phosphoric Aeid
Sulfuric Acid (1994 and after "Acid
Aerosols" Only)
Mctribuzin
Accphatc
Chromium Compounds
Chlorodifluoro me thane
Malcic Anhydride
M-xylcnc
Dicofol
Aldicarb
Linuron
F-llivl ninmpvllhincnrhamntfi
#
Reporting
Chemical
24
24
22
21
17
17
14
13
12
12
12
12
11
11
11
11
10
10
9
9
9
8
8
8
8
8
8
8
7
6
6
6
6
6
6
6
6
6
5
5
5
5
5
5
5
5
5
5
5-
4
4
4
4
4
4
4
4
4
4
4
3
3
3
3
3
3
3
T
Potw
Transfers
5
9
463
0
0
0
25397
263
5
4367
5
0
4
5
255
5
0
73
0
5
5
10
57107
0
0
0
0
0
5
0
0
5
0
2
0
250
12
6319
5
5
0
0
5
1
0
0
0
0
62
0
0
0
0
940
5
0
0
0
0
250
1
0
0
0
0
0
0
s
Disposal
Transfers
475
2599
3600
823
6017
2750
5
584
2191
2278
2005
2077
231
5673
9267
260
100655
276"
5
1250.
3896
533
360
250
5
5
4778
15862
1770
16605
250
755
1200
26
1255
25549
11257
SQO
Recycling Treatment
Transfers Transfers
43314
4851510 731777
16070 11478
6962
1207
3370
47248
8700
61666
,126038
4150
2081
392714
9772
1518
23721
807182 150224
28161
754 1500
2730
520
231855
1132
1388
'. 1453
1617
125
2082
3091
2497
2171
38081
2120
. 380
6580
21 6309
'. 22147
'. 941
4603
8041
17525
1448
1108
13905
29000
19277 3555
1310
1630
250
13213
15800
155
'. 410
. • 250
32289
Qfilfi
Energy
Recovery
Transfers
1020414
45
1186991
221410
214836
557
Total
Transfers
43794
6606309
31611
7830
1207
3370
72645
14980
64421
1317401
4739
4272
614128
12055
3778
25803
1172473
33907
11521
2995
525
332520
58239
1664
0
0
1458
2867
130
2082
3091
6398
2171
38616
2480
630
6842
6319
6340
10
22147
0
5724
21023
9811
17525
18053
1358
14722
30200
26
22832
1310
2570
1510
0
25549
0
13213
16050
11413
0
0
410
250
32289
0
1 0701
Avg
Transfer
Per
Facility
1,825
275,263
1,437
373
71
198
5,189
1,152
5,368
109,783
395
356
55,830
1,096
, 343
2,346
1 17,247
3,391
1,280
333
, 58
41,565
7,280
208
0
0
182
358
19
347
515
1,066
362
6,436
413
105
1,140
1,053
1,268
2
4,429
0
1,145
4,205
1,962
3,505
3,611
272
2,944
7,550
7
5,708
328
643
378
0
6,387
.0
3,303
4,013
3,804
0
0
137
83
10,763
0
3407
Sector Notebook Project
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Chemical Releases and Transfers
Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)
#
Chemical Name Reporting Potw
Chemical Transfers
'araquat Dichloride
'ropachlor
'luometuron
)imethylamine Dicamba
Carboxin
Copper
ithoprop
'hiophanate-methyl
'endimethalin
[exazinone
ithylenebisdithiocarbamic Acid, Salts and
Esters
'richlorfon
'arathion
Dichlorvos
S,s,s-tributyltrithiophosphate
2,4-db
,4-dichlorobenzene
,2-dichloroethane
Morobenzene
"henol
Diethanolamine
24-dp
i*j-r «p
Naled
lydrazine
,3-dichloropropylene
'ropanil
Ametryn
^ycloate
Sromoxynil
2,4-d Butoxyethyl Ester
Sodium Dicamba
Dipotassium Endothall
vlolinate
Uhlorpyrifos Methyl
Zinc fFume or Dust)
Citric Acid
lesmethrin
Jesmedipham
Thiophanate Ethyl
fhiobencarb
fhiodicarb
"ropiconazole
Dyfluthrin
?omesafen
Juizalofop-ethyl
^actofen
Bifenthrin
Myclobutanil
Antimony Compounds
Chlorophenols
Cyanide Compounds
Diisocyanates
^ead Compounds
Carbon Tetrachloride
formic Acid .
Isopropyl Alcohol (Manufacturing,
Strong-acid Process Only, No Supplies)
i-J.n-dimethylformamide
Methoxychlor
Vinyl Chloride
Tert-buryl Alcohol
2-methyllactonitrile
Triphenyltin Hydroxide
Hexachlorocyclopentadiene
Dicyclopentadiene
Dimethyl Sulfate
Methyl Ethyl Ketone
Dichloran
P-yylene
3
3
3
3
3
3
3
3
3
3
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
32
15
235
0
2
0
0
0
0
250
0
0
6
0
0
0
0
0
0
5
0
5
0
0
0
0
0
0
0
750
0
. 0
0
0
0
0
0
6
5
0
0
0
0
0
0
6
0
0
6
0
0
0
250
6
0
0
6
0
0
0
o
Energy
Disposal Recycling Treatment Recovery Total
Transfers Transfers Transfers Transfers Transfers
5
1505
255
384
250
1167
250
51
39
28
1388
4405
4930
250
1332
2501
250
132
2290
830
54765
250
6490
13785
''. 390
'. 1105
'. 250
12830
'. 145
116
792
1365
'. 1700
! 5
3
3176
'. 51325
1744
9700
1006
8
3256
'. 250
1256
500
'. 600
492
'. 18411
'. 1019
5
3069
48
'. 1198
4
65000
'. 2800
4055
500
416
! 3735
814
7sri
287
6505
15525
255
776
0
1355
1167
0
750
12830
0
104 249
116
792
1365
0
1700
0
61
42
3181
0
51325
1744
9700
1034
1396
3256
750
250
21 5682
500
0
0
600
492
'. 4930
18666
1332
1019
2506
0
3319
48
132
670 4158
4
'. 65000
0
3630
529" 529
2331 61401
500
0
416
0
800 4535
0
0
814
7.50
Avg
Transfer
Per
Facility
96
2,168
5,175
85
259
0
452
389
0
250
6,415
0
125
58
396
683
G
850
0
31
21
1,591
0
25,663
872
4,850
517
698
1,628
375
125
2,841
250
C
(
300
246
2,465
9,333
666
510
1,253
0
1,660
24
132
4,155
*
65,000
l
3,630
529
61,401
50<
1
416
'
4,535
814
. 2«i
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Chemical Releases and Transfers
Table 17: 1996 TRI Transfers for Agricultural Chemicals Facilities (SIC 2879)
by Number and Facilities Reporting (Transfers reported in pounds/year)
#
Chemical Name Reporting Potw Disposa
Chemical . Transfers Transfers
1,3-butadiene 1 0
Cyclohcxanol 0
N-hcxane 0
Pyridine 8506
Propoxur
Di(2-cthylhcxyl) Phthalate 2
HcNachlorobcnzcnc 0
1,2,4-lrichlorobenzcne 0
2,4-dichlorophcnol 0
TrieUiylaminc 1 0
Hydraquinonc 1 250
Folpet 1 0
Merphos 1 0
Oxydcmcton Methyl 1
Bromacil 1 0
Methyl Isothiocyanate 1 0
Pcrchloromcthyl Mcrcaptan 1 0
Methyl Isooyanatc 1 0
Pcbulate 1 0 500
Bcnfluralin 1
Nitrapyrin 1
Ttiallatc 1 0 509
Dodinc 1 0
Dimethyl Chlorothiophosphate 1 0
Tcmcphos 1
Tcibacil 1
Hydrogen Fluoride 1 , 0
Bromine 1 750
Mcvinplios 1 0
Phosphinc 1 0
Creosote 1 5
Zincb 1
Fenbutatin Oxide 1
Alachlor 1 0
Bcnomyl 1
Oryzalin 1
Oxydinzon 1 0
Aluminum Phosphide 1
Dcndiocarb 1
Pronamidc 1 0
Toluene Diisocyanatc (Mixed Isomers) 1
Propetamphos 1 0 1000
Amitrnz 1 .
Tcbuthiuron 1 0
Diflubcnzuron 1
Sulprofos 0
Dinocap
Fcnpropalhrin
Prolenofos
Qxyfluorfen
Triadimcfon 0
Vinclozolin
Fcnvalerate 0
Dimcthipin
Triclopyr Triethylammonium Salt 0
Fcnarimol
Acifluorfcn, Sodium Salt 0
Chlorsulfuron 1 0
Fluvalinatc 1
Chlorimuron Ethyl 1 0
Tribcnuron Methyl • 1 • 0
193** 106.917 306.983
Recycling
Transfers
5,762.544
Energj
; Treatment Recover}
Transfers Transfer
35289
20740 5f
1033
3849 221f
7920 89C
61668 256J
868
250
676
500
602
8600
250
500
937
3994
82
"980:7
36604
17387
2.494.611 2,654.437
Avg
i. Transfer
t Total Per
> Transfers Facility
0 0
35289 35,289
20796 20,796
8506 8,506
1035 1,035
6064 6,064
8810 8,810
0 0
64236 64,236
250 250
0 0
0 0
868 868
0 0
0 0
0 0
750 - 750
1185 1,185
500 500
0 0
6 6
750 750
0 0
0 0
607 607
8600 8,600
250 250
500 500
1000 1,000
937 937
6 6
6 6
3994 3,994
82 82
6 6
9807 9,807
36604 36,604
17387 17,387
11,325,492 58.681
** Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
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Chemical Releases and Transfers
Top 10 TRI Releasing Agricultural Chemical Companies
The TRI database contains a detailed compilation of self-reported, facility-
specific chemical releases. The top reporting facilities for the agricultural
chemical industries are listed below in Tables 18.; 19, 20, and 21. Facilities
that have reported the primary SIC codes covered under this notebook appear
on Table 18 for fertilizers and Table 20 for pesticides and miscellaneous
agricultural chemicals. Tables 19 and 21 contain additional facilities that
have reported the SIC codes covered within this report, and one or more SIC
codes that are not within the scope of this notebook. Therefore, the second
list includes facilities that conduct multiple operations ~ some that are under
the scope of this notebook, and some that are not. Currently, the facility-level
data do not allow pollutant releases to be broken apart by industrial process.
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Chemical Releases and Transfers
Table 18: Top 10 TRI Releasing Fertilizer Manufacturing and Mixing Facilities
(SIC 2873, 2874, 2875)*
Rank
1
2
3
4
5
6
7
8
9
10
Facility
PCS Phosphate Co., Inc. - Aurora, NC
CF Ind. Inc. - Donaldsonville, LA
Unocal Agricultural Products - Kenai, AK
Terra Nitrogen - Catoosa, OK
PCS Nitrogen Fertilizer LP - Millington, TN
IMC Nitrogen Co. - East Dubuque, IL
IMC-Agrico - Uncle Sam, LA
Triad Chemical - Donaldsonville, LA
IMC-Agrico - Mulberry, FL
Farmland Ind. Inc. - Enid, OK
Total
Total TRI Releases in Pounds
13,202,617
5,823,740
4,715,420
4,147,000
3,957,624
3,954,025
3,570,548
3,478,835
3,161,160
2,804,790
45,615,759
Source: US Toxics Release Inventory Database, 1996.
'Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.
Table 19: Top 10 TRI Releasing Facilities Reporting Fertilizer Manufacturing and
Mixing SIC Codes *
Rank
1
2
3
4
5
6
7
8
9
10
Facility
PCS Phosphate Co. Inc. - Geismar, LA
PCS Phosphate Co. Inc. - Aurora, NC
IMC Agrico Co. - St. James, LA
Du Pont - Beaumont, TX
Rubicon Inc. - Geismar, LA
Monsanto Co. - Luling, LA
Coastal Chemical Co. - Cheyenne, WY
PCS Phosphate - White Springs, FL
Vicksburg Chemical Co. - Vicksburg, MS
CF Ind. Inc. - Donaldsonville, LA
SIC Codes Reported in TRI
2873,2874,2819
2874
2873,2874,2819
2822, 2865, 2869, 2873
2865, 2869, 2873
2879, 2834, 2873, 2869, 2819
2813, 2819, 2869, 2873, 2899
2874,2819
2819,2873,2812
2873
Total
Total TRI
Releases in
Pounds
23,192,580
13,202,617
12,794,917
10,880,836
8,327,597
7,742,540
7,674,410
6,961,770
6,139,460
5,823,740
102,740,467
Source: US Toxics Release Inventory Database, 1996.
' Being included on this list does not mean that the release is associated with non-compliance with environmental
laws.
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Chemical Releases and Transfers
Table 20: Top 10 TRI Releasing Pesticide and Miscellaneous Agricultural Chemicals
Facilities (SIC 2879)*
Rank
1
2
3
4
5
6
7
8
9
10
Facility
BASF Corp. - Beaumont, TX
Rhone-Poulenc Ag. Co. - Woodbine, GA
American Cyanamid Co. - Palmyra, MO
Zeneca Inc. - Perry, OH
Farmland Ind. Inc. - Saint Joseph, MO
Zeneca Inc. - Pasadena, TX
Bayer Corp. - Kansas City, MO
Trical Inc. - Hollister, CA
FMC Corp. - Institute, WV
McLaughlin Gormley King Co. - Chaska, MN
Total
Total TRI Releases in Pounds
649,472
242,293
227,942
178,291
162,037
149,968
45,881
32,447
22,195
21,611
1,732,137
Source: US Toxics Release Inventory Database, 1996.
* Being included on this list does not mean that the release is associated with non-compliance with environmental
laws
Table 21: Top 10 TRI Releasing Facilities Reporting Pesticide and Miscellaneous
Agricultural Chemicals SIC Codes *
Rank
1
2
3
4
5
6
7
8
9
10
Facilitv
Monsanto Co. - Luling, LA
Monsanto - Alvin, TX
Uniroyal Chemical Co. - Geismar, LA
Du Pont - La Porte, TX
Dow Chemical USA - Midland, MI
Novartis Crop Protection Inc., - St. Gabriel, LA
Tippecanoe Laboratories - Shadeland, IN
Clinton Laboratories - Clinton, IN
Ciba Specialty Chemicals Corp. - Mclntosh,
AL
Du Pont - Belle, WV
SIC Codes Reported in TRI
2879, 2834, 2873, 2869, 2819
2869,2819,2841,2879
2822, 2869, 2879
2819, 2869, 2879
2800, 2819, 2821, 2834, 2869, 2879
2819,2865,2869,2879
2834, 2879
2833, 2879
2879,2821,2865,3069
2821, 2869, 2879
Total
Total TRI
Releases in
Pounds
7,742,540
7,718,029
2,936,127
2,633,242
1,523,414
1,488,589
1,206,435
1,158,105
1,067,347
795,378
28,269,206
Source: US Toxics Release Inventory Database, 1996.
* Being included on this list does not mean that the release is associated with non-compliance with environmental
laws
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Chemical Releases and Transfers
IV.B. Summary of Selected Chemicals Released
The following is a synopsis of current scientific toxicity and fate information
for the top chemicals (by weight) that facilities within this sector self-reported
as released to the environment based upon 1995 TRI data. Because this
section is based upon self-reported release data, it does not attempt to provide
information on management practices employed by the sector to reduce the
release of these chemicals. Information regarding pollutant release reduction
over time may be available from EPA's TRI and 33/50 programs, or directly
from the industrial trade associations that are listed in Section IX of this
document. Since these descriptions are cursory, please consult these sources
for a more detailed description of both the chemicals described in this
section, and the chemicals that appear on the full list of TRI chemicals
appearing in Section IV.A.
The brief descriptions provided below were taken from the Hazardous
Substances Data Bank (HSDB) and the Integrated Risk Information System
(IRIS), both accessed via TOXNET.2 The discussions of toxicity describe the
range of possible adverse health effects that have been found to be associated
with exposure to these chemicals. These adverse effects may or may not
occur at the levels released to the environment. Individuals interested in a
more detailed picture of the chemical concentrations associated with these
adverse effects should consult a toxicologist or the toxicity literature for the
chemical to obtain more information. The effects listed below must be taken
in context of these exposure assumptions that are explained more fully within
the full chemical profiles in HSDB. For more information on TOXNET,
contact the TOXNET help line at 1 -800-231 -3 766.
*\
TOXNET is a computer system run by the National Library of Medicine that includes a number of toxicological
databases managed by EPA, National Cancer Institute, and the National Institute for Occupational Safety and
Health. For more information on TOXNET, contact the TOXNET help line at 800-231-3766. Databases included in
TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART (Developmental and
Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources), EMICBACK
(Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous
Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of Chemical
Substances), and TRI (Toxic Chemical Release Inventory). HSDB contains chemical-specific information on
manufacturing and usage, chemical and physical properties, safety and handling, toxicity and biomedical effects,
pharmacology, environmental fate and exposure potential, exposure standards and regulations, monitoring and
analysis methods, and additional references.
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Chemical Releases and Transfers
Ammonia3 (CAS: 7664-41-7)
Sources. Ammonia is the primary nitrogen source for all nitrogenous
fertilizers and ammonium phosphatic fertilizers.
Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, and
upper respiratory system.
Ecologically, ammonia is a source of nitrogen (an essential element for
aquatic plant growth), and may therefore contribute to eutrophication of
standing or slow-moving surface water, particularly in nitrogen-limited
waters such as the Chesapeake Bay. In addition, aqueous ammonia is
moderately toxic to aquatic organisms.
Carcinogenicity. There is currently no evidence to suggest that ammonia is
carcinogenic.
Environmental Fate. Ammonia combines with sulfate ions in the
atmosphere and is washed out by rainfall, resulting in rapid return of
ammonia to the soil and surface waters.
Ammonia is a central compound in the environmental cycling of nitrogen.
Ammonia in lakes, rivers, and streams is converted to nitrate.
Physical Properties. Ammonia is a colorless gas at atmospheric pressure,
but is shipped as a liquefied compressed gas. It is soluble to about 34 percent
in water and has a boiling point of-28 degrees F. Ammonia is corrosive and
has a pungent odor.
Phosphoric Acid (CAS: 7664-38-2)
Sources. Phosphoric acid is the primary phosphorous source used for
phosphatic fertilizers.
Toxicity. Phosphoric acid is toxic by ingestion and inhalation, and is an
irritant to skin and eyes. The toxicity of phosphoric acid is related to its
corrosivity as an acid, with ulceration of membranes and tissues with which
it comes in contact. Because it is a source of phosphorous, an essential
element for aquatic plant growth, phosphoric acid may contribute to
eutrophication of standing or slow-moving surface water, particularly in
phosphorous-limited waters such as the Great Lakes.
The reporting standards for ammonia were changed in 1995. Ammonium sulfate is deleted from the list and
threshold and release determinations for aqueous ammonia are limited to 10 percent of the total ammonia present in
solution. This change will reduce the amount of ammonia reported to TRI. Complete details of the revisions can be
found in 40 CFR Part 372.
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Chemical Releases and Transfers
Carcinogenicity. There is currently no evidence to suggest that phosphoric
acid is carcinogenic.
Environmental Fate. The acidity of phosphoric acid may be reduced readily
by natural water hardness minerals. The phosphate will persist until used by
plants as a nutrient.
Physical Properties. Phosphoric acid is a thick, colorless, and odorless
crystalline solid, often used in an aqueous solution. Its boiling point is 415 °
F and it is soluble in water.
Nitrate compounds
Sources. Many different nitrate compounds are formed during nitrogenous
fertilizer production.
Toxicity. Nitrate compounds that are soluble in water release nitrate ions
which can cause both human health and environmental effects. Human
infants exposed to aqueous solutions of nitrate ion can develop a condition
in which the blood's ability to carry oxygen is reduced. This reduced supply
of oxygen can lead to damaged organs and death. Because it is a source of
nitrogen, an essential element for aquatic plant growth, nitrate ion may
contribute to eutrophication of standing or slow-moving surface water,
particularly in nitrogen-limited waters, such as the Chesapeake Bay.
Carcinogenicity. There is currently no evidence to suggest that nitrate
compounds are carcinogenic.
Environmental Fate. Nitrogen in nitrate is the form of nitrogen most
available to plants. In the environment, nitrate ion is taken up by plants and
becomes part of the natural nitrogen cycle. Excess nitrate can stimulate
primary production in plants and can produce changes in the dominant
species of plants, leading to cultural eutrophication and ultimately to
deterioration of water quality.
Methanol (CAS: 67-56-1)
Sources. Methanol is generated in ammonia production. It is also used as a
solvent and for equipment cleaning in pesticide formulations.
Toxicity. Methanol is readily absorbed from the gastrointestinal tract and the
respiratory tract and is toxic to humans in moderate to high doses; In the
body, methanol is converted into formaldehyde and formic acid. Methanol
is excreted as formic,acid. Observed toxic effects at high dose levels
generally include central nervous system damage and blindness. Long-term
Sector Notebook Project
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Agricultural Chemical Industry
Chemical Releases and Transfers
exposure to high levels of methanol via inhalation cause liver and blood
damage in animals.
Ecologically, methanol is expected to have low toxicity to aquatic organisms.
Concentrations lethal to half the organisms of a test population are expected
to exceed one mg methanol per liter water. Methanol is not likely to persist
in water or to bioaccumulate in aquatic organisms.
Carcinogenicity. There is currently no evidence to suggest that methanol is
carcinogenic.
Environmental Fate. Methanol is highly volatile and flammable. Liquid
methanol is likely to evaporate when left exposed. Methanol reacts in air to
produce formaldehyde which contributes to the formation of air pollutants.
In the atmosphere it can react with other atmospheric chemicals or be washed
out by rain. Methanol is readily degraded by microorganisms in soils and
surface waters.
Physical Properties. Methanol is a colorless liquid with a characteristic
pungent odor. It is miscible with water, and its boiling point is 147°F.
Sulfuric Acid (CAS: 7664-93-9)
Sources. Sulfuric acid is a raw material of most fertilizer products.
Toxicity. Concentrated sulfuric acid is corrosive. In its aerosol form,
sulfuric acid has been implicated in causing and exacerbating a variety of
respiratory ailments.
Ecologically, accidental releases of solution forms of sulfuric acid may
adversely affect aquatic life by inducing a transient lowering of the pH (i.e.,
increasing the acidity) of surface waters. In addition, sulfuric acid in its
aerosol form is also a component of acid rain. Acid rain can cause serious
damage to crops and forests.
Carcinogenicity. There is currently no evidence to suggest that sulfuric acid
is carcinogenic.
Environmental Fate. Releases of sulfuric acid to surface waters and soils
will be neutralized to an extent due to the buffering capacities of both
systems. The extent of these reactions will depend on the characteristics of
the specific environment.
Physical Properties. Sulfuric acid is an oily, odorless liquid which can be
colorless to dark-brown. It is miscible, and its boiling point is 554°F.
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Sulfuric acid reacts violently with water with evolution of heat and is
corrosive to metals. Pure sulfuric acid is a solid below 51 °F.
IV.C. Other Data Sources
The toxic chemical release data obtained from TRI captures only about 236
of the facilities in the Fertilizer, Pesticide, and Agricultural Chemical
Industry. However, it allows for a comparison across years and industry
sectors. Reported chemicals are limited to the approximately 600 TRI
chemicals. A portion of the emissions from agricultural chemical facilities,
therefore, are not captured by TRI. The EPA Office of Air Quality Planning
and Standards has compiled air pollutant emission factors for determining the
total air emissions of priority pollutants (e.g., total hydrocarbons, SOx, NOx,
CO, particulates, etc.) from many chemical manufacturing and formulating
sources.
The Aerometric Information Retrieval System (AIRS) contains a wide range
of information related to stationary sources of air pollution, including the
emissions of a number of air pollutants which may be of concern within a
particular industry. With the exception of volatile organic compounds
(VOCs), there is little overlap with the TRI chemicals.reported above. Table
22 summarizes annual releases (from the industries for which a Sector
Notebook Profile was prepared) of carbon monoxide (CO), nitrogen dioxide
(NO2), particulate matter of 10 microns or less (PM10), sulfur dioxide (SO2),
and volatile organic compounds (VOCs).
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Table 22: Air Pollutant Releases by Industry Sector (tons/year)
Industry Sector
Metal Mining
Non-Fuel, Non-Metal Mining
Textiles
Lumber and Wood Products
Wood Furniture and Fixtures
Pulp and Paper -
Printing
Inorganic Chemicals
Plastic Resins and Man-made Fibers
Pharmaceuticals
Organic Chemicals
Agricultural Chemicals
Petroleum Refining
Rubber and Plastic
Stone, Clay, Glass and Concrete
Iron and Steel
Metal Castings
Nonferrous Metals
Fabricated Metal Products
Electronics and Computers
Motor Vehicle Assembly
Aerospace
Shipbuilding and Repair
Ground Transportation
Water Transportation
Air Transportation
Fossil Fuel Electric Power
Dry Cleaning
CO
4,951
31,008
8,164
139,175
3,659
584,817
8,847
242,834
15,022
6,389
112,999
12,906
299,546
2,463
92,463
982,410
115,269
311,733
7,135
27,702
19,700
4,261
109
153,631
179
1,244
399,585
145
NO2
49,252
21,660
33,053
45,533
3,267
365,901
3,629
93,763
36,424
17,091
177,094
38,102
334,795
10,977
335,290
158,020
10,435
31,121
11,729
7,223
31,127
5,705
866
594,672
476
960
5,661,468
. 781
PM10
21,732
44,305
1,819
30,818
2,950
37,869
539
6,984
- 2,027
1,623
13,245
4,733
25,271
3,391
58,398
36,973
14,667
12,545
2,811
1,230
3,900
89.0
762
2,338
676
133
221,787
• 10
PT
9,478
16,433
38,505
18,461
3,042
535,712
1,772
150,971
65,875
24,506
129,144
14,426
592,117
24,366
290,017
241,436
4,881
303,599
17,535
8,568
29,766
757
2,862
9,555
712
147
13,477,367
725
S02
1,202
9,183
26,326
95,228
84,036
177,937
88,788
52,973
71,416
31,645
162,488
62,848
292,167
110,739
21,092
67,682
17,301
7,882
108,228
46,444
125,755
3,705
4,345
101,775
3,514
1,815
42,726
7,920
voc
119,761
138,684
7,113
74,028
5,895
107,676
1,291
34,885
7,580
4,733
17,765
8,312
36,421
6,302
198,404
85,608
21,554
23,811
5,043
3,464
6,212
10,804
707
5,542
3,775
144
719,644
40
Source: United States EPA Office of Air and Radiation, AIRS Database. 1 997.
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Chemical Releases and Transfers
IV.D. Comparison of Toxic Release Inventory Between Selected Industries
The following information is presented as a comparison of pollutant release
and transfer data across industrial categories. It is provided to give a general
sense as to the relative scale of TRI releases and transfers within each sector
profiled under this project. Please note that the following figure and table do
not contain releases and transfers for industrial categories that are not
included in this project, and thus cannot be used to draw conclusions
regarding the total release and transfer amounts that are reported to TRI.
Similar information is available within the annual TRI Public Data Release
Book.
Figure 19 is a graphical representation of a summary of the TRI data for the
Fertilizer, Pesticide, and Agricultural Chemical Industry and the other sectors
profiled in separate notebooks. The bar graph presents the total TRI releases
and total transfers on the vertical axis. Industry sectors are presented in the
order of increasing SIC code. The graph is based on the data shown in Table
23 and is meant to facilitate comparisons between the relative amounts of
releases and transfers both within and between these sectors. Table 23 also
presents the average releases per facility in each industry. The reader should
note that differences in the proportion of facilities captured by TRI exist
between industry sectors. This can be a factor of poor SIC matching and
relative differences in the number of facilities reporting to TRI from the
various sectors. In the case of the Fertilizer, Pesticide, and Agricultural
Chemical Industry, the 1995 TRI data presented here covers 236 facilities.
These facilities listed SIC 2873,2874,2875, or 2879 as a primary SIC code.
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Figure 19: Summary of 1995 TRI Releases and Transfers by Industry
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Aericultural Chemical Industry
Chemical Releases and Transfers
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-------
Agricultural Chemical Industry
Pollution Prevention Opportunities
V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place. Some
companies have creatively implemented pollution prevention techniques that
improve efficiency and increase profits while at the same time minimizing
environmental impacts. This can be done in many ways such as reducing
material inputs, re-engineering processes to reuse by-products, improving
management practices, and substituting toxic chemicals with those less toxic.
Some smaller facilities are able to actually get below regulatory thresholds
just by reducing pollutant releases through aggressive pollution prevention
policies.
The Pollution Prevention Act of 1990 established a national policy of
managing waste through source reduction, which means preventing the
generation of waste. The Pollution Prevention Act also established as
national policy a hierarchy of waste management options for situations in
which source reduction cannot be feasiblely implemented. In the waste
management hierarchy, if source reduction is not feasible the next alternative
is recycling of wastes, followed by energy recovery, and waste treatment as
a last alternative.
In order to encourage these approaches, this section provides both general and
company-specific descriptions of some pollution prevention advances that
have been implemented within the Fertilizer, Pesticide, and Agricultural
Chemical Industry. While the list is not exhaustive, it does provide core
information that can be used as the starting point for facilities interested in
beginning their own pollution prevention projects. This section provides
summary information from activities that may be, or are being implemented
by this sector. When possible, information is provided that gives the context
in which the technique can be used effectively. Please note that the activities
described in this section do not necessarily apply to all facilities that fall
within this sector. Facility-specific conditions must be carefully considered
when pollution prevention options are evaluated, and the full impacts of the
change must examine how each option affects air, land and water pollutant
releases.
The Fertilizer, Pesticide, and Agricultural Chemical Industry uses many
pollution prevention (P2), recycle and reuse, and water conservation
practices. Wastewaters are primarily generated not by the production or
formulating processes themselves but by cleaning operations of the process
areas and associated equipment. Because the wastewaters are mostly
cleaning rinsates and not waters of reaction, the pollution prevention
practices are not process-specific. There are many P2, recycle and reuse, and
water conservation practices that are widely accepted and practiced by the
Fertilizer, Pesticide, and Agricultural Chemical Industry today.
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Pollution Prevention Opportunities
These pollution prevention, recycle and reuse, and water conservation
practices fall into three groups: production practices, housekeeping practices,
and practices that use equipment that, by design, promote pollution
prevention. Some of these practices and equipment conserve water, others
reduce the amount of fertilizer or pesticide product in the wastewater, and
still others may prevent the generation of a wastewater altogether (USEPA,
1996). A number of common P2 practices are listed below.
Production practices include:
• . triple-rinsing raw material shipping containers directly into the
formulation
• scheduling production to minimize cleanouts
• segregating processing/formulating/packaging equipment by:
- individual product '
- solvent-based versus water-based formulations
- products that contain similar active ingredients in
different concentrations
• storing interior equipment rinse waters for use in formulating the
same product
• packaging products directly from formulation vessels
• using raw material drums for packaging final products
• dedicating equipment (possibly only mix tank or agitator) for
"hard-to-clean" formulations
Housekeeping practices include:
• performing preventive maintenance on all valves, fittings, and
pumps
• placing drip pans under leaky valves and fittings or under any
valves or fittings where hoses or lines are routinely connected and
disconnected
• cleaning up spills or leaks in outdoor bulk containment areas to
prevent contamination of storm water
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Equipment that promotes pollution prevention by reducing or eliminating
waste water generation includes:
, • low-volume/high-pressure hoses
• spray nozzle attachments for hoses
• squeegees and mops
• low-volume/recirculating floor scrubbing machines
• portable steam cleaners
• drum triple rinsing stations
• roofs over outdoor tank farms (USEPA, 1996)
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Table 24: Waste Minimization Methods for the Fertilizer, Pesticide, and
Agricultural Chemical Industry
Waste Stream || Waste Minimization Methods
Equipment Cleaning Wastes
Spills and Area Washdowns
Off-Specification Products
Containers
Air Emissions
Miscellaneous Wastewater Streams
Maximize production runs.
Store and reuse cleaning wastes.
Use of wiper blades and squeegees.
Use of low- volume, high-efficiency
cleaning.
Use of plastic or foam "pigs."
Use of dedicated vacuum system.
Use of dry cleaning methods.
Use of recycled water for initial cleanup.
Actively involved supervision.
Strict quality control and automation.
Reformulating off-spec batches.
Return containers to supplier and or reuse
as directed.
Triple rinse containers.
Drums with liners versus plastic drums or
bags.
Segregating solid waste.
Control bulk storage air emissions.
Dedicate dust collection systems.
Use automatic enclosed cut-in hoppers.
Eliminate emissions of ammonia from
reaction of anhydrous ammonia and
phosphoric acid.
Pave high spillage areas.
Source: Guides to Pollution Prevention, The Pesticide Formulating Industry, Center for
Environmental Research Information, United States EPA, Cincinnati, Ohio, 1990.
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Pollution Prevention Opportunities
V.A. Equipment Cleaning
Shipping Container/Drum Cleaning Operations
Fertilizer and pesticide facilities frequently receive raw materials in
containers such as 55-gallon plastic or steel drums or 30-gallon fiber drams.
In some cases, the empty drums are returned to the supplier, but usually the
facility is responsible for disposal of the drums. The simplest, most cost-
effective, and best approach to prevent pollution associated with cleaning
drams and shipping containers is to rinse empty drums prior to disposal to
capture the raw material residue for direct reuse in future formulations of the
same product. In this way, the facility not only eliminates a potential highly
contaminated wastewater source, but is also able to recover the product value
of the raw material and avoids costs associated with storage of the wastewater
(USEPA, 1996). However, pesticide chemicals formulating and packaging
facilities and pesticide repackaging and refilling facilities should consult the
List of Pollution Prevention Alternative Practices and ensure compliance with
the effluent guidelines and standards found in 40 CFR 455 Subparts C and E
before implementing pollution prevention techniques listed in this section.
Rinsing procedures for pesticide drums are provided in 40 CFR Part 165.
The most common method of drum rinsing in the agrichemical industry is
triple rinsing. After a drum containing AIs or pesticide products is emptied,
it should be triple rinsed with the solvent that will be used in the formulation.
This method prevents the creation of a rinsate that cannot be added directly
to the formulation (e.g., a facility will not create a water-based rinsate when
producing a solvent-based product). Note in some cases the label may
specify how to rinse.
Some facilities use a high-pressure, low-volume wash system equipped with
a hose and a spray nozzle to triple rinse drums; volumes of five to fifteen
gallons of water per drum have been reported. EPA has identified many
facilities that reuse these rinsates directly in product formulations. Other
facilities treat drum rinsate and reuse the effluent for further drum or
equipment rinsing. If the rinsate cannot be reused directly in product
formulations, another effective method to reduce wastewater generation
during shipping container/drum cleaning processes is the use of drum rinsing
stations (USEPA, 1996).
One facility uses a three-cell station for triple-rinsing drums. The water in
the first cell is used for the first rinse, the water in the second cell is used for
the second rinse, and the water in the third cell is used for the final rinse. The
rinse water in the first cell is reused until it is visually too contaminated to
effectively clean the drums. At that time, it is removed from the cell (for
treatment) and the rinse water from the second cell is transferred into the first
cell. The rinse water from the third cell is transferred into the second cell,
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Pollution Prevention Opportunities
and the third cell is refilled with treated effluent from their treatment system.
Each cell contains approximately 100 gallons of water; approximately 70
drums can be rinsed before the first cell requires water changing (USEPA,
1996).
Another site uses a unique, closed-loop set-up for emptying and triple rinsing
raw material drums. The system was designed by the facility for several
purposes: to aid it in emptying and cleaning drums and performing the triple
rinse, to eliminate the need for storage of the water (or solvent) for reuse, and
to prevent mathematical errors by the operators during the weighing out of
raw materials and water (or solvent). The system consists of two 55-gallon
drums, a formulation tank, and connecting hoses. One of the drums is
permanently fixed on top of the formulation tank. The formulation tank and
drum are situated on a load cell (used for weighing). The second drum,
which is full of raw material, is placed on the ground next to the formulation
tank.. One hose is used to vacuum out the raw material and transfer it to the
drum on the formulations tank/load cell. The other hose is equipped with a
doughnut-shaped nozzle that provides the triple rinse by spraying the interior
of the now empty raw material drum. The rinsate that is created by the triple
rinse procedure is automatically removed by the vacuum line and is
transferred to the drum on the formulation tank/load cell.
The load cell can be used to weigh the amount of raw material and/or rinsate
that is added to the formulation by zeroing out the weight of the tank and
drum. This allows the volume of both raw material and rinse water (or
solvent) to be factored into the total volume of water (or solvent) required in
the formulation. The drum on top of the formulation tank is equipped with
a spring-loaded valve that enables the operator to take weight measurements
prior to emptying the contents of the drum into the mix tank. This set-up has
almost completely eliminated operator math errors and related formulation
specification problems.
Bulk Tank and Equipment Cleaning
Pesticide formulating and fertilizer mixing facilities sometimes produce large
quantities of formulated pesticide and fertilizer products and receive large
quantities of raw materials used to produce those products. Those products
and raw materials are stored on site in bulk tanks. The tanks are typically
rinsed only when it becomes necessary to use the tank to store a different
material. Each time the facility-switches the product stored in a bulk tank, the
tank is rinsed. Bulk tanks are sometimes also rinsed.at the end of a season as
a part of general maintenance (USEPA, 1996). Pesticide formulating and
fertilizer mixing facilities should consult the List of Pollution Prevention
Alternative Practices and ensure compliance with the effluent guidelines and
standards found in 40 CFR Part 455 Subparts C and E before implementing
pollution prevention techniques involving bulk tank and other equipment
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Agricultural Chemical Industry
Pollution Prevention Opportunities
cleaning.
Product changeover cleanings can be eliminated or greatly reduced by
dedicating equipment to specific products or groups of products. Although
entire lines are not generally dedicated, there are many facilities that dedicate
tanks to formulation mixing only, thereby eliminating one of the most highly
contaminated wastewater streams generated at pesticide formulating and
packaging facilities. Facilities also dedicate lines to the production of a
specific product type, such as water-based versus solvent-based products,
thereby reducing the number of cleanings required, and allowing greater reuse
of the cleaning water or solvent.
Another effective pollution prevention technique is to schedule production
to reduce the number of product changeovers, which reduces the number of
equipment interior cleanings required. Facilities may also reduce the number
of changeover cleanings required or the quantity of water or solvent used for
cleaning by scheduling products in groups. Products may lend themselves to
a particular production sequence if they have common active ingredients,
assuming the products also have the same solvent base (including water).
Where other raw material cross-contamination problems are not a concern,
no cleaning would be required between changeover. Facilities that have
implemented this technique have conducted testing to ensure that product
quality is not adversely affected (USEPA, 1996).
Scheduling production according to packaging type can reduce changeover
cleanings of packaging equipment. Packaging lines are often able to handle
containers of different sizes; a slight adjustment to one packaging line, such
as adding a short length of hose, may prevent the use of an entirely different
set of packaging equipment that would also require cleaning. Packaging can
also be performed directly out of the formulation vessels to avoid using and
subsequently cleaning interim storage tanks and transfer hoses.
Another effective pollution prevention and water conservation technique to
minimize the quantity of rinse water generated by equipment interior cleaning
is the use of water hoses equipped with hand-control devices (for example,
spray-gun nozzles such as those used on garden hoses). This practice
prevents the free flow of water from unattended hoses. Another technique to
conserve water is the use of high-pressure, low-volume washers instead of
ordinary hoses. One of the facilities visited indicated that, by using high-
pressure washers, they reduced typical equipment interior rinse volumes from
twenty gallons per rinse to ten gallons per rinse (USEPA, 1996).
Steam cleaning can also be a particularly effective method to clean viscous
products that otherwise require considerable volumes of water and/or the
addition of a detergent to remove. Many facilities have access to steam from
boilers on site; however, if there is no existing source of steam, steam
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cleaning equipment can be purchased. Although steam generation can
increase energy consumption and add NOX and SOX pollutants to the
atmosphere, there are benefits to be gained. Facilities may end up creating
a much smaller volume of wastewater and may potentially avoid the need to
use detergents or other cleaning agents that could prevent product recovery.
However, steam would be a poor choice for cleaning applications where
volatile organic solvents or inerts are part of the product, as the steam would
accelerate the volatilization of the organic compounds.
Facilities also clean equipment interiors by using squeegees to remove the
product from the formulation vessel and by using absorbent "pigs" to clean
products out of the transfer lines before equipment rinsing. These techniques
minimize the quantity of cleaning water required, although they generate a
solid waste stream requiring disposal. Regardless of whether or not residual
product is removed from equipment interiors before rinsing, if certain
conditions are met, equipment interior rinsate can typically be reused as
make-up water the next time that a water-based product is being formulated
with the same chemical (USEPA, 1996). Pesticide chemicals formulating
and packaging facilities and pesticide repackaging and refilling facilities
should consult the List of Pollution Prevention Alternative Practices and
ensure compliance with the effluent guidelines and standards found in 40
CFR Part 455 Subparts C and E before implementing pollution prevention
techniques involving bulk tank and other equipment cleaning.
One facility uses a unique method of cleaning to reduce the volume of water
needed to clean equipment interiors. At this facility, the production lines are
hooked to dedicated product storage tanks. Prior to rinsing these production
lines, the facility uses air to "blow" the residual product in the line back to
product storage. Not only will these lines require less water to clean, but the
residual product that is blown back to storage is not diluted and should not
affect the product specifications in any way.
Another facility drastically reduced dichloromethane usage at several plants
by switching to soap and water for cleaning. This change enabled the facility
to cut its target chemicals by two-thirds. The facility also reduced the release
of carbon tetrachloride, and installed a closed-loop recycling system, to
reduce water usage (CMA, 1993).
Aerosol Container Leak Testing
No method of eliminating wastewater from test baths has been identified.
However, the volume of water used may be minimized by using a contained
(or batch) water bath as opposed to a continuous overflow water bath. A
contained water bath is completely emptied and refilled with water when
required, based upon visual inspection by the operator. Therefore, the
quantity of wastewater generated depends on the frequency of refilling and
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the volume of the bath (200 gallons is a typical volume of the contained water
baths). One facility uses a contained water bath and heats the bath with steam
to ensure that the temperature of the cans reaches 130°F. This facility
indicated that steam condensation causes some overflow that exits the bath
via a standpipe. A continuous overflow bath would probably generate more
wastewater per production unit than a batch water bath (USEPA, 1996).
One facility has installed a diatomaceous earth filter on one DOT test bath.
The facility recirculates the bath water through the filter to remove
contaminants such as oil and grease and suspended solids. The filtered water
is then reused in the bath, thereby extending the usefulness of the bath water.
The facility anticipates they will dispose of the filter as nonhazardous waste.
Another facility uses a can-washing step prior to the DOT test bath,
presenting an additional source of wastewater. This can washing is
performed at the operator's discretion to reduce the quantity of contaminants
entering the bath water. The effectiveness of this step has not been
quantitatively determined (USEPA, 1996).
Laboratory Equipment Cleaning
Many pesticide formulating and packaging facilities operate on-site
laboratories for conducting quality control tests of raw materials and
formulated products. Wastewater is generated from these tests and from
cleaning glassware used in the tests. One effective pollution prevention/reuse
technique during laboratory equipment cleaning operations is to dedicate
laboratory sinks to certain products, and collect any wastewater generated
from the testing of those products either for reuse in the same product or for
transfer back to the AI manufacturer or product registrant. In the cases where
the facility uses solvents in conjunction with the quality control tests
performed in the laboratory, the solvent-contaminated water may not be able
to be reused in the process (USEPA, 1996).
V.B. Process Changes
Storage Tanks
One method to reduce the amount of wastewater from ammonium nitrate
production is to incorporate a wastewater evaporator system which reduces
the amount of contaminated cooling water discharge. The wastewater passes
through a series of evaporation steps whereby the vapors are used as wash
water in the calcium carbonate filters and the concentrated solution is
pumped to the neutralizers where it is mixed with the acidic nitrogen-
phosphate solution and used to regulate the nitrogen-phosphate nutrient ratio
of the fertilizer. Through this modified technology, steam and electric energy
consumption increases somewhat, but such increases are balanced by the
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more effective utilization of nitrogen and the reduction of wastewater. More
information on this method can be found in "Waste Water Evaporation
Process for Fertilizer Production Technology," Compendium on Low and
Non-waste Technology, United Nations Economic and Social Counsel.
(http://es.inel.gov/studies/cs244.html)
Many methods are available for reducing the amount of emissions resulting
from fixed roof storage tanks. Some of these methods include use of
conservation vents, conversion to floating roof tanks, use of nitrogen
blanketing to suppress emissions and reduce material oxidation, use of
refrigerated condensers, use of lean-oil or carbon, absorbers, or use of vapor
equilibration lines. When dealing with volatile materials, employment of one
or more of these methods can result in cost savings to the facility by reducing
raw material losses and improving compliance with local air quality
requirements (USEPA, 1996).
Air Emission Control Systems
Agricultural chemical facilities often produce large quantities of dust which
are collected from numerous sources. The chemical composition of the
various dust sources can vary widely. Opportunities often exist to reduce
waste generation through segregation of these waste dusts and particulates.
At Daly-Herring Co., in Kingston, NC, dust streams from several different
production areas were handled by a single baghouse. Since all of the streams
were mixed, none of the waste could be recycled to the process that generated
them. By installing separate dedicated baghouses for each production line,
all of the collected pesticide dust could be recycled.- The initial investment
for the equipment was $9,600. The payback period was only ten months.
Daly-Herring saved over $9,000 per year in disposal costs and $2,000 per
year in raw material costs (Hunt, 1989).
At FMC Corp. in Fresno, CA, common dust collectors were used by multiple
production systems. Due to the cross contamination of materials, recycling
was impossible. To promote recycling, the company compartmentalized the
dust collectors with each compartment serving a single source. All collected
materials are analyzed for cross contamination and if none exists, they are
reused in the succeeding product batch. Other work involved the installation
of self-contained dust collectors at each inlet hopper dump station so that
captured dust can be returned to the system (USEPA, 1996).
Facilities may also use wet scrubbers to control air emissions. Some facilities
may only need a wet scrubber on one particular process (i.e., a dedicated
scrubber). These facilities have been able to reuse the scrubber blowdown or
changed-out scrubber water as make-up water in the formulation of that
particular product. Some facilities with nondedicated scrubbers have been
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able to use the scrubber blowdown or changed-out scrubber water for floor
or equipment exterior cleaning (USEPA, 1996).
Microprill Formation
Microprill formation resulting from partially plugged orifices of melt spray
devices can increase fine dust loading and emissions. Certain designs
(spinning buckets) and practices (vibration of spray plates) help reduce
microprill formation. Reducing the ambient air temperature reduces
emissions because the air flow required to cool prills and the formation of
fumes are decreased at lower temperatures.
V.C. Good Housekeeping
Floor/Wall/Equipment Exterior Cleaning
During processing, formulating, and packaging operations, the exteriors of
equipment may become soiled from drips, spills, and dust (especially
equipment located near dry lines). The floors in the area become dirty in the
same manner and also from normal traffic. Facility workers clean the
equipment exteriors and floors for general housekeeping purposes, and to
keep sources of product contamination to a minimum. When water is used,
these cleaning procedures become a source of wastewater.
Wastewater can again be minimized through the use of high-pressure, low-
volume washers rather than ordinary water hoses. Additionally, some
facilities practice steam cleaning rather than water cleaning of equipment
exteriors to reduce the amount of wastewater generated (USEPA, 1996).
Instead of hosing down the exterior of a piece of equipment, some facilities
wipe equipment exteriors with rags or use a solvent cleaner, such as a
commercially available stainless steel cleaner. This practice avoids
generating a wastewater stream, but does create a solid waste that, depending
on the solvent used, could be considered a hazardous waste. Squeegees are
also used to clean equipment exteriors and floors, and are not disposed of
after single uses. It may be possible to dedicate squeegees to a certain line or
piece of equipment, but using squeegees may still require using some water
(USEPA, 1996).
Some facilities use automated floor scrubbers, which replace the practice of
hosing down floors. Floor scrubbers are mechanical devices that continually
recirculate cleaning water to clean flat, smooth surfaces with circulating
brushes. During operation, the scrubber collects the cleaning water in a small
tank that is easily emptied after the cleaning process, or at a later date. Using
a floor scrubbing machine can require as little as five to fifteen gallons of
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cleaning solution (typically water) per use. A mop and a single bucket of
water can also be used in place of a hose. Floor mopping can generate as
little as ten gallons of water per cleaning depending on the size of the surface
to be cleaned (USEPA, 1996).
A number of facilities reuse their floor wash water with and without filtering.
One facility has set up its production equipment on a steel-grated platform
directly above a collection sump. Following production, the equipment and
the floor of the platform, on which the operator stands when formulating
product, are rinsed and the water is allowed to flow into the sump. A pump
and a filter have been installed in the sump area to enable the operator to
transfer this rinsate back into the formulation tank for the next formulation.
This sump is also connected to floor trenches in the packaging area for the
same product. When the exterior of the packaging equipment and the floors
in this area are rinsed, this water is directed to the trenches and eventually
ends up in the collection sump for reuse (USEPA, 1996).
Leaks and Spills Clean-Up
Dry products that have leaked or spilled can be vacuumed or swept without
generating any wastewater. Liquid leaks and spills can be collected into a
trench or sump (for reuse, discharge, or disposal) with a squeegee, leaving
only a residue to be mopped up or hosed down if further water cleanup is
required. Liquid leaks and spills can also be cleaned up using absorbent
material, such as absorbent pads or soda ash. For an acidic product, soda ash
or a similar base material will also serve to neutralize the spill. If a residue
remains, some water may be used for mopping up or hosing the area down,
but methods to reduce floor wash should be implemented whenever possible.
Many facilities clean up leaks and spills from water-based products with
water and then solvent-based products with absorbent materials. Using an
absorbent material may be the best practice for cleaning up small scale
solvent-based leaks and spills; however, EPA does recognize that this
material then needs to be disposed of (cross-media transfer). Therefore, good
housekeeping practices may be even more important in the case of organic
solvent-based product spills and leaks because, if not prevented, these spills
and leaks may have to be cleaned up with absorbent material and disposed of
(USEPA, 1996).
Direct reuse of products which have leaked or spilled is another possible
pollution prevention technique. If drip pans or other containers are used to
catch leaks and spills, the material (either water-based or solvent-based) can
be immediately reused in the product being processed, formulated, or
packaged, or stored for use in the next product batch. Collection hoppers or
rubs can be installed beneath packaging fillers to capture spills and
immediately direct the spills back to the fillers. Leaks or spills around bulk
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storage tanks can be contained by dikes, which, in fact, are often required by
state regulations (USEPA, 1996).
Precipitation Runoff
Precipitation runoff includes all precipitation that falls on facility surfaces
that are believed to be contaminated. Contaminated precipitation runoff can
be prevented by bringing all operations indoors, as many facilities have done,
or by covering outdoor storage tanks and dikes with roofs, which has also
been done at many facilities. The roofs would ideally extend low enough to
prevent crosswinds from blowing rain into spill-containment dikes. To
prevent rainwater contamination, the drain spouts and gutters should conduct
roof runoff to areas away from process operations, and the roofs should be
kept in good repair (USEPA, 1996).
If operations remain outdoors, a transfer, or containment pad should be
installed with a sump or other means of collecting rinse water. The pad
should be constructed of asphalt or concrete and maintained with crack sealer
and a top coat sealer to control infiltration. The pad should also be large
enough to contain wind-blown participates from dry materials. If pads are
cleaned before a rainfall, then uncontaminated precipitation runoff may be
directly discharged to surface drains (CFA, 1996). Facilities can also monitor
the water in a containment system by periodically testing for a variety of
contaminants.
It may be difficult for facilities that do not require large volumes of water to
reuse all the precipitation collected in the containment system. These
facilities could keep the containment system free of any spilled pesticides
through good housekeeping practices so that precipitation falling into the
containment system does not become contaminated. Some facilities house
their pesticide bulk storage area inside a building or under a covered area to
eliminate precipitation from collecting in the containment system, as well as
to protect the area from vandalism and severe weather (USEPA, 1996).
Containment Pad in the Loading/Unloading Area
Agrichemical dealers sometimes install loading/containment pads in the
operation area to contain and collect any product spills that may occur during
pesticide loading operations. The pad is usually installed contiguous to the
bulk storage tanks and the repackaging of products into smaller containers.
Facilities may also conduct all their portable cleaning operations, such as
rinsing minibulk containers, directly on the pad in order to contain and collect -
the jrinsates. • - • •
The pad is normally constructed of concrete and is sloped to a sump area.
Some facilities divide the sump area into individual collection basins so that
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the facilities can segregate wastewaters contaminated by different products
and reuse these wastewaters for applications. For instance, facilities in .the
Midwest frequently have two collection basins; one basin collects
wastewaters contaminated with corn herbicides and the other collects
wastewaters contaminated with soybean herbicides. As part of this collection
system, some facilities install one or more tanks to'store waste water until it
can be applied to land, while other facilities use portable minibulk tanks to
store the wastewater. When facilities collect wastewaters that must be
segregated by different types of products, multiple storage tanks are used to
avoid contamination (USEPA, 1996).
V. D. Energy Efficiency
Installation of a Feed-Gas Saturator
A mixture of steam and natural gas with a volumetric ratio of steam to carbon
of about 3.5:1 is reacted in the primary reformer of reforming ammonia
plants. Most of the steam is generated from heat sources within the plant, but
the balance of the steam has to be produced in auxiliary boilers. This retrofit
permits the use of low-level heat from the flue gases, which would otherwise
be lost, to be used in saturating the feed natural gas with water. This
generates extra steam which replaces some of the steam generated in the
boiler (UNEP, 1996).
Modification of Convection Coils
As a result of other modifications, the temperature profile of the flue gases
may change considerably in the cold-leg section of the primary reformer.
This change can be compensated for by replacing the low steam superheat
coil with a new one with additional rows of tubes and heavier fins on all
tubes (UNEP, 1996).
Low-heat Removal of Carbon Dioxide
The traditional systems used for removal of carbon dioxide from the process
steam uses hot potassium carbonate which requires heat for regeneration.
This heat comes from process heat but needs to be supplemented with
external steam. A new low-heat removal system is now available, which uses
flashing for part of the regeneration process, and requires less external heat
(UNEP, 1996).
Ammonia Synthesis Modifications
Ammonia Converter Retrofit
The vertical quench-type converters are changed from axial flow to radial
flow, greatly decreasing the pressure drop across the converter which in turn
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allows the use of smaller size catalyst with a larger surface area. This
improved catalyst yields a higher conversion per pass, generating a lower
recycle volume. The lower recycle volume and the lower pressure drop result
in reduced energy requirements. This modification yields an increase
effective capacity of the ammonia converter of about 35 percent (UNEP,
1996).
Addition of Process Computer
A dedicated process computer can be installed along with other on-line
analysis and control systems to monitor and control key variables. With this
system, continuous set point changes are possible to optimize the operation
of several plant areas such as hydrogen/nitrogen ratio, steam/carbon ratio,
synthesis loop purge, methane leakage, converter control, and refrigeration
purge (UNEP, 1996).
Hydrogen Recovery from the Purge Gas
Inert gases must be pumped from the plant to avoid their buildup in the
system. This purge is carried out by removing a side stream of synthesis gas
after recovering the ammonia. By installing the proper recovery system, the
hydrogen in this gas mixture can be recovered decreasing the energy
requirements of the process by about five percent or permitting an increase
of about five percent in production capacity (UNEP, 1996).
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Federal Statutes and Regulations
VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS
This section discusses the federal regulations that may apply to this sector.
The purpose of this section is to highlight and briefly describe the applicable
federal requirements, and to provide citations for more detailed information.
The three following sections are included:
• Section VI.A contains a general overview of major statutes
• Section VLB contains a list of regulations specific to this industry
• Section VI.C contains a general discussion on State regulation of
pesticides
• Section VI.D contains a list of pending and proposed regulatory
requirements
The descriptions within Section VI are intended solely for general
information. Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily describe all
applicable environmental requirements. Moreover, they do not constitute
formal interpretations or clarifications of the statutes and regulations. For
further information, readers should consult the Code of Federal Regulations
(CFR) and other state or local regulatory agencies. EPA Hotline contacts are
also provided for each major statute.
VI.A. General Description of Major Statutes
Federal Insecticide, Fungicide, and Rodenticide Act
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was first
passed in 1947, and amended numerous times, most recently by the Food
Quality Protection Act (FQPA) of 1996. FIFRA provides EPA with the
authority to oversee, among other things, the registration, distribution, sale
and use of pesticides. The Act applies to all types of pesticides, including
insecticides, herbicides, fungicides, rodenticides, and antimicrobials. FIFRA
covers both intrastate and interstate commerce.
Establishment Registration
Section 7 of FIFRA requires that establishments producing pesticides, or
active ingredients used in producing a pesticide subject to FIFRA, register
with EPA. Registered establishments must report the types and amounts of
pesticides and active ingredients they produce. The Act also provides EPA
inspection authority and enforcement authority for facilities/persons that are
not in compliance with FIFRA.
Product Registration
Under section 3 of FIFRA, all pesticides (with few exceptions) sold or
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distributed in the United States must be registered by EPA. Pesticide
registration is very specific and generally allows use of the product only as
specified on the label. Each registration specifies the use site, i.e., where the
product may be used, and amount that may be applied. The person who seeks
to register the pesticide must file an application for registration. The
application process often requires either the citation or submission of
extensive environmental, health, and safety data.
To register a pesticide, the EPA Administrator must make a number of
findings, one of which is that the pesticide, when used in accordance with
widespread and commonly recognized practice, will not generally cause
unreasonable adverse effects on the environment.
FIFRA defines "unreasonable adverse effects on the environment" as "(1) any
unreasonable risk to man or the environment, taking into account the
economic, social, and environmental costs and benefits of the use of the
pesticide, or (2) a human dietary risk from residues that result from a use of
a pesticide in or on any food inconsistent with the standard under section 408
of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 346a);"
Under FIFRA section 6(a)(2), after a pesticide is registered, the registrant
must also notify EPA of any additional facts and information concerning
unreasonable adverse environmental effects of the pesticide. Also, if EPA
determines that additional data are needed to support a registered pesticide,
registrants may be required to provide additional data. If EPA determines
that the registrant(s) did not comply with their request for more information,
the registration can be suspended under FIFRA section 3(c)(2)(B) and section
4.
Use Restrictions
As a part of the pesticide registration, EPA must classify the product for
general use, restricted use, or general for some uses and restricted for others
(Miller, 1993). For pesticides that may cause unreasonable adverse effects
on the environment, including injury to the applicator, EPA may require that
the pesticide be applied either by or under the direct supervision of a certified
applicator.
Reregistration
Due to concerns that much of the safety data underlying pesticide
registrations becomes outdated and inadequate, in addition to providing that
registrations be reviewed every 15 years, FIFRA requires EPA to reregister
all pesticides that were registered prior to 1984 (section 4). After reviewing
existing data, EPA may approve the reregistration, request additional data to
support the registration, cancel, or suspend the pesticide.
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Tolerances and Exemptions
A tolerance is the maximum amount of pesticide residue that can be on a raw
product and still be considered safe. Before EPA can register a pesticide that
is used on raw agricultural products, it must grant a tolerance or exemption
from atolerance (40 CFR sections 163.10 through 163.12). Under the Federal
Food, Drug, and Cosmetic Act (FFDCA), a raw agricultural product is
deemed unsafe if it contains a pesticide residue, unless the residue is within
the limits of a tolerance established by EPA or is .exempt from the
requirement.
Cancellation and Suspension
EPA can cancel a registration if it is determined that the pesticide or its
labeling does not comply with the requirements of FIFRA or causes
unreasonable adverse effects on the environment (Haugrud, 1993).
In cases where EPA believes that an "imminent hazard" would exist if a
pesticide were to continue to be used through the cancellation proceedings,
EPA may suspend the pesticide registration through an order and thereby halt
the sale, distribution, and usage of the pesticide. An "imminent hazard" is
defined as an unreasonable adverse effect on the environment or an
unreasonable hazard to the survival of a threatened or endangered species that
would be the likely result of allowing continued use of a pesticide during a
cancellation process.
When EPA believes an emergency exists that does not permit a hearing to be
held prior to suspending, EPA can issue an emergency order which makes the
suspension immediately effective.
Imports and Exports
Under FIFRA section 17(a), pesticides not registered in the United States and
intended solely for export are not required to be registered provided that the
exporter obtains and submits to EPA, prior to export, a statement from the
foreign purchaser acknowledging that the purchaser is aware that the product
is not registered in the United States and cannot be sold for use there. EPA
sends these statements to the government of the importing country. FIFRA
sets forth additional requirements that must be met by pesticides intended
solely for export. The enforcement policy for exports is codified in sections
40 CFR sections 168.65, 168.75, and 168.85.
Under FIFRA section 17(c), imported pesticides and devices must comply
with United States pesticide law. Except where exempted by regulation or
statute, imported pesticides must be registered. FIFRA section 17(c) requires
that EPA be notified of the arrival of imported pesticides and devices. This
is accomplished through the Notice of Arrival (NOA) (EPA Form 3540-1),
which is filled out by the importer prior to importation and submitted to the
EPA regional office applicable to the intended port of entry. United States
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Customs regulations prohibit the importation of pesticides without a
completed NOA. The EPA-reviewed and signed form is returned to the
importer for presentation to United States Customs when the shipment arrives
in the United States NOA forms can be obtained from contacts in the EPA
Regional Offices or www.epa.gov/oppfeadl/international/noalist.htm.
Additional information on FIFRA and the regulation of pesticides can be
obtained from a variety of sources, including EPA's Office of Pesticide
Programs' homepage at -www.epa.gov/pesticides, EPA's Office of
Compliance, Agriculture and Ecosystem Division at
http://es.epa.gov/oeca/agecodiv.htm, or The National Agriculture
Compliance Assistance Center toll-free, at 888-663-2155 or
http://es.epa.gov/oeca/ag. Other sources include the National Pesticide
Telecommunications Network toll-free at 800-858-7378 and the National
Antimicrobial Information Network toll-free at 800-447-6349.
Clean Water Act
The primary obj ective of the Federal Water Pollution Control Act, commonly
referred to as the Clean Water Act (CWA), is to restore and maintain the
chemical, physical, and biological integrity of the nation's surface waters.
Pollutants regulated under the CWA are classified as either "toxic"
pollutants; "conventional" pollutants, such as biochemical oxygen demand
(BOD), total suspended solids (TSS), fecal coliform, oil and grease, and pH;
or "non-conventional" pollutants, including any pollutant not identified as
either conventional or priority.
The CWA regulates both direct and "indirect" dischargers (those who
discharge to publicly owned treatment works). The National Pollutant
Discharge Elimination System (NPDES) permitting program (CWA section
402) controls direct discharges into navigable waters. Direct discharges or
"point source" discharges are from sources such as pipes and sewers.
NPDES permits, issued by either EPA or an authorized state (EPA has
authorized 43 states and 1 territory to administer the NPDES program),
contain industry-specific, technology-based and water quality-based limits
and establish pollutant monitoring and reporting requirements. A facility that
proposes to discharge into the nation's waters must obtain a permit prior to
initiating a discharge. A permit applicant must provide quantitative analytical
data identifying the types of pollutants present in the facility's effluent. The
permit will then set forth the conditions and effluent limitations under which
a facility may make a discharge.
Water quality-based discharge limits are based on federal or state water
quality criteria or standards, that were designed to protect designated uses of
surface waters, such as supporting aquatic life or recreation. These standards,
unlike the technology-based standards, generally do not take into account
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technological feasibility or costs. Water quality criteria and standards vary
from state to state, and site to site, depending on the use classification of the
receiving body of water. Most states follow EPA guidelines which propose
aquatic life and human health criteria for many of the 126 priority pollutants.
Storm Water Discharges
In 1987 the CWA was amended to require EPA to establish a program to
address storm water discharges. In response, EPA promulgated NPDES
permitting regulations for storm water discharges. These regulations require
that facilities with the following types of storm water discharges, among
others, .apply for an NPDES permit: (1) a discharge associated with industrial
activity; (2) a discharge from a large or medium municipal storm sewer
system; or (3) a discharge which EPA or the state determines to contribute to
a violation of a water quality standard or is a significant contributor of
pollutants to waters of the United States.
The term "storm water discharge associated with industrial activity" means
a storm water discharge from one of 11 categories of industrial activity
defined at 40 CFR section 122.26. Six of the categories are defined by SIC
codes while the other five are identified through narrative descriptions of the
regulated industrial activity. If the primary SIC code of the facility is one of
those identified in the regulations, the facility is subject to the storm water
permit application requirements. If any activity at a facility is covered by one
of the five narrative categories, storm water discharges from those areas
where the activities occur are subject to storm water discharge permit
application requirements.
Those facilities/activities that are subject to storm water discharge permit
application requirements are identified below. To determine whether a
particular facility falls within one of these categories, the regulation should
be consulted.
Category i: Facilities subject to storm water effluent guidelines, new source
performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products (except
paperboard containers and products); SIC 28-chemicals and allied products
(except drugs and paints); SIC 29-petroleum refining; SIC 311-leather
tanning and finishing; SIC 32 (except 323)-stone, clay, glass, and concrete;
SIC 33-primary metals; SIC 3441-fabricated structural metal; and SIC 373-
ship and boat building and repairing.
Category iii: Facilities classified as SIC 10-metal mining; SIC 12-coal
mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
mining.
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Category iv: Hazardous waste treatment, storage, or disposal facilities.
Category v: Landfills, land application sites, and open dumps that receive
or have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Category viii: Facilities classified as SIC 40-railroad transportation; SIC 41 -
local passenger transportation; SIC 42-trucking and warehousing (except
public warehousing and storage); SIC.43-U.S. Postal Service; SIC 44-water
transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
storage stations and terminals.
Category ix: Sewage treatment works.
Category x: Construction activities except operations that result in the
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products; SIC
21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
paper and paperboard products; SIC 27-printing, publishing, and allied
industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
allied products; SIC 30-rubber and plastics; SIC 31-leather and leather
products (except leather and tanning and finishing); SIC 323-glass products;
SIC 34-fabricated metal products (exc'ept fabricated structural metal); SIC 35-
industrial and commercial machinery and computer equipment; SIC 36-
electronic and other electrical equipment and components; SIC 37-
transportation equipment (except ship and boat building and repairing); SIC
38-measuring, analyzing, and controlling instruments; SIC 39-miscellaneous
manufacturing industries; and SIC 4221-422-5-public warehousing and
storage.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that goes to a
publicly owned treatment works (POTW). The national pretreatment program
(CWA section 307(b)) controls the indirect discharge of pollutants to
POTWs by "industrial users." Facilities regulated under section 307(b) must
meet certain pretreatment standards. The goal of the pretreatment program
is to protect municipal wastewater treatment plants from damage that may
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occur when hazardous, toxic, or other wastes are discharged into a sewer
system and to protect the quality of sludge generated by these plants.
EPA has developed technology-based standards for industrial users of
POTWs. Different standards apply to existing and new sources within each
category. "Categorical" pretreatment standards applicable to an industry on
a nationwide basis are developed by EPA. In addition, another kind of
pretreatment standard, "local limits," are developed by the POTW in order to
assist the POTW in achieving the effluent limitations in its NPDES permit.
Regardless of whether a state is authorized to. implement either the NPDES
or the pretreatment program, if it develops its own program, it may enforce
requirements more stringent than federal standards.
Wetlands
Wetlands, commonly called swamps, marshes, fens, bogs, vernal pools,
playas, and prairie potholes, are a subset of "waters of the United States," as
defined in section 404 of the CWA. The placement of dredge and fill material
into wetlands and other water bodies (i.e., waters of the United States) is
regulated by the United States Army Corps of Engineers (Corps) under 33
CFR Part 328. The Corps regulates wetlands by administering the CWA
section 404 permit program for activities that impact wetlands. EPA's
authority under section 404 includes veto power of Corps permits, authority
to interpret statutory exemptions and jurisdiction, enforcement actions, and
delegating the section 404 program to the states.
EPA's Office of Water, at (202) 260-5700, will direct callers,with questions
about the CWA to the appropriate EPA office. EPA also maintains a
bibliographic database of Office of Water publications which can be
accessed through the Ground Water and Drinking Water Resource Center at
(202) 260-7786.
Oil Pollution Prevention Regulation
Section 31 l(b) of the CWA prohibits the discharge of oil, in such quantities
as may be harmful, into the navigable waters of the United States and
adjoining shorelines. The EPA Discharge of Oil regulation, 40 CFR Part
110, provides information regarding these discharges. The Oil Pollution
Prevention regulation, 40CFRPartll2, under the authority of section 311 (j)
of the CWA, requires regulated facilities to prepare and implement Spill
Prevention Control and Countermeasure (SPCC) plans. The intent of a SPCC
plan is to prevent the discharge of oil from onshore and offshore non-
transportation-related facilities. In 1990, Congress passed the Oil Pollution
Act which amended section 311(j) of the CWA to require facilities that
because of their location could reasonably be expected to cause "substantial
harm" to the environment by a discharge of oil to develop and implement
Facility Response Plans (FRP). The intent of a FRP is to provide for planned
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responses to discharges of oil.
A facility is SPCC-regulated if the facility, due to its location, could
reasonably be expected to discharge oil into or upon the navigable waters of
the United States or adjoining shorelines, and the facility meets one of the
following criteria regarding oil storage: (1) the capacity of any aboveground
storage tank exceeds 660 gallons, or (2) the total aboveground storage
capacity exceeds 1,320 gallons, or (3) the underground storage capacity
exceeds 42,000 gallons. The 40 CFR section 112.7 contains the format and
content requirements for a SPCC plan. In New Jersey, SPCC plans can be
combined with DPCC plans required by the state provided there is an
appropriate cross-reference index to the requirements of both regulations at
the front of the plan.
According to the FRP regulation, a facility can cause "substantial harm" if it
meets one of the following criteria: (1) the facility has a total oil storage
capacity greater than or equal to 42,000 gallons and transfers oil over water
to or from vessels; or (2) the facility has a total oil storage capacity greater
than or equal to 1 million gallons and meets any one of the following
conditions: (i) does not have adequate secondary containment, (ii) a discharge
could cause "injury" to fish and wildlife and sensitive environments, (iii) shut
down a public drinking water intake, or (iv) has had a reportable oil spill
greater than or equal to 10,000 gallons in the past 5 years. Appendix F of 40
CFR Part 112 contains the format and content requirements for a FRP. The
FRPs that meet EPA's requirements can be combined with United States
Coast Guard FRPs or other contingency plans, provided there is an
appropriate cross-reference index to the requirements of all applicable
regulations at the front of the plan.
For additional information regarding SPCC plans, contact EPA's RCRA,
Superfund, and EPCRA Hotline, at (800) 424-9346. Additional documents
and resources can be obtained from the hotline's homepage at
•www.epa.gov/epaoswer/hotline. The hotline operates weekdays from 9:00
a.m. to 6:00 p.m., EST, excluding federal holidays.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in drinking water.
The law authorizes EPA to develop national drinking water standards and to
create a joint federal-state system to ensure compliance with these standards.
The SDWA also directs EPA to protect underground sources of drinking
water through the control of underground injection of fluid wastes.
EPA has developed primary and secondary drinking water standards under
its SDWA authority. EPA and authorized states enforce the primary drinking
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water standards that are contaminant-specific concentration limits that apply
to certain public drinking water supplies. Primary drinking water standards
consist of maximum contaminant level goals (MCLGs), which are
non-enforceable health-based goals, and maximum contaminant levels
(MCLs), which are enforceable limits set generally as close to MCLGs as
possible, considering cost and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR Parts
144-148) is a permit program which protects underground sources of drinking
water by regulating five classes of injection wells. The UIC permits include
design, operating, inspection, and monitoring requirements. Wells used to
inject hazardous wastes must also comply with RCRA corrective action
standards in order to be granted a RCRA permit, and must meet applicable
RCRA land disposal restrictions standards. The UIC permit program is often
state/tribe-enforced, since EPA has authorized many states/tribes to
administer the program. Currently, EPA shares the UIC permit program
responsibility in seven states and runs the program in 10 states and on all
tribal lands.
The SDWA also provides for a federally-implemented Sole Source Aquifer
program, which prohibits federal funds from being expended on projects that
may contaminate the sole or principal source of drinking water for a given
area, and for a state-implemented Wellhead Protection program, designed to
protect drinking water wells and drinking water recharge areas.
The SDWA Amendments of 1996 require states to develop and implement
source water assessment programs (SWAPs) to analyze existing and potential
threats to the quality of the public drinking water throughout the state. Every
state is required to submit a program to EPA and to complete all assessments
within 3 ¥2 years of EPA approval of the program. SWAPs include: (1)
delineating the source water protection area; (2) conducting a contaminant
source inventory; (3) determining the susceptibility of the public water supply
to contamination from the inventories sources; and (4) releasing the results
of the assessments to the public.
EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
and distributes guidance pertaining to SDWA standards. The Hotline
operates from 9:00 a.m. through 5:30 p.m., EST, excluding federal holidays.
Visit the website at http://www.epa.gov/ogwdwfor additional material.
Resource Conservation and Recovery Act
The Solid Waste Disposal Act (SWDA), as amended by the Resource
Conservation and Recovery Act (RCRA) of 1976, addresses solid and
hazardous waste management activities. The Act is commonly referred to as
RCRA. The Hazardous and Solid Waste Amendments (HSWA) of 1984
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strengthened RCRA's waste management provisions and added Subtitle I,
which governs underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
260-299) establish a "cradle-to-grave" system governing hazardous waste
from the point of generation to disposal. RCRA hazardous wastes include the
specific materials listed in the regulations (discarded commercial chemical
products, designated with the code "P" or "U"; hazardous wastes from
specific industries/sources, designated with the code "K"; or hazardous
wastes from non-specific sources, designated with the code "F") or materials
which exhibit a hazardous waste characteristic (ignitability, corrosivity,
reactivity, or toxicity and designated with the code "D").
Entities that generate hazardous waste are subject to waste accumulation,
manifesting, and recordkeeping standards. A hazardous waste facility may
accumulate hazardous waste for up to 90 days (or 180 days depending on the
amount generated per month) without a permit or interim status. Generators
may also treat hazardous waste in accumulation tanks or containers (in
accordance with the requirements of 40 CFR section 262.3 4) without a permit
or interim status.
Facilities that treat, store, or dispose of hazardous waste are generally
required to obtain a RCRA permit. Subtitle C permits for treatment, storage,
or disposal facilities contain general facility standards such as contingency
•plans, emergency procedures, recordkeeping and reporting requirements,
financial assurance mechanisms, and unit-specific standards. RCRA also
contains provisions (40 CFR Part 264 Subparts I and S) for conducting
corrective actions which govern the cleanup of releases of hazardous waste
or constituents from solid waste management units at RCRA treatment,
storage, or disposal facilities.
Although RCRA is a federal statute, many states implement the RCRA
program. Currently, EPA has delegated its authority to implement various
provisions of RCRA to 47 of the 50 states and two United States territories.
Delegation has not been given to Alaska, Hawaii, or Iowa.
Most RCRA requirements are not industry specific but apply to any company
that generates, transports, treats, stores, or disposes of hazardous waste. Here
are some important RCRA regulatory requirements:
Criteria for Classification of Solid Waste Disposal Facilities and
Practices (40 CFR Part 257) establishes the criteria for determining which
solid waste disposal facilities and practices pose a reasonable probability of
adverse effects on health or the environment. The criteria were adopted to
ensure non-municipal, non-hazardous waste disposal units that receive
conditionally exempt small quantity generator waste do not present risks to
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human health and environment.
Criteria for Municipal Solid Waste Landfills (40 CFR Part 258)
establishes minimum national criteria for all municipal solid waste landfill
units, including those that are used to dispose of sewage sludge.
Identification of Solid and Hazardous Wastes (40 CFR Part 261)
establishes the standard to determine whether the material in question is
considered a solid waste and, if so, whether it is a hazardous waste or is
exempted from regulation.
Standards for Generators of Hazardous Waste (40 CFR Part 262)
establishes the responsibilities of hazardous waste generators including
obtaining an EPA ID number, preparing a manifest, ensuring proper
packaging and labeling, meeting standards for waste accumulation units, and
recordkeeping and reporting requirements. Generators can accumulate
hazardous waste on-site for up to 90 days (or 180 days depending on the
amount of waste generated) without obtaining a permit.
Land Disposal Restrictions (LDRs) (40 CFR Part 268) are regulations
prohibiting the disposal of hazardous waste on land without prior treatment.
Under the LDRs program, materials must meet treatment standards prior to
placement in a RCRA land disposal unit (landfill, land treatment unit, waste
pile, or surface impoundment). Generators of waste subject to the LDRs
must provide notification of such to the designated TSD facility to ensure
proper treatment prior to disposal.
Used Oil Management Standards (40 CFR Part 279) impose management
requirements affecting the storage, transportation, burning, processing, and
re-refining of the used oil. For parties that merely generate used oil,
regulations establish storage standards. For a party considered a used oil
processor, re-refiner, burner, or marketer (one who generates and sells
off-specification used oil directly to a used oil burner), additional tracking
and paperwork requirements must be satisfied.
Tanks and Containers Standards (40 CFR Part 264-265, Subpart CC)
contains unit-specific standards for all units used to store, treat, or dispose of
hazardous waste. Tanks and containers used to store hazardous waste with a
high volatile organic concentration must meet emission standards under
RCRA. Regulations require generators to test the waste to determine the
concentration of the waste, to satisfy tank and container emissions standards,
and to inspect and monitor regulated units. These regulations apply to all
facilities who store such waste, including large quantity generators
accumulating waste prior to shipment offsite.
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• Underground Storage Tanks (USTs) containing petroleum and hazardous
substances are regulated under Subtitle I of RCRA. Subtitle I regulations (40
CFR Part 280) contain tank design and release detection requirements, as
well as financial responsibility and corrective action standards for USTs. The
UST program also includes upgrade requirements for existing tanks that were
to be met by December 22, 1998.
• Boilers and Industrial Furnaces (BIFs) that use or burn fuel containing
hazardous waste must comply with design and operating standards. BIF
regulations (40 CFR Part 266, Subpart H) address unit design, provide
performance standards, require emissions monitoring, and, in some cases,
restrict the type of waste that may be burned.
EPA'sRCRA, Superfund, andEPCRA Hotline, at (800) 424-9346, responds
to questions and .distributes guidance regarding all RCRA regulations.
Additional documents and resources can be obtained from the hotline's
homepage at http://www.epa.gov/epaoswer/hotline. The RCRA Hotline
operates weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal
holidays. •
Comprehensive Environmental Response, Compensation, and Liability Act
The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA
to respond to releases, or threatened releases, of hazardous substances that
may endanger public health, welfare, or the environment. The CERCLA also
enables EPA to force parties responsible for environmental contamination to
clean it up or to reimburse the Superfund for response or remediation costs
incurred by EPA. The Superfund Amendments and Reauthorization Act
(SARA) of 1986 revised various sections of CERCLA, extended the taxing
authority for the Superfund, and created a free-standing law, SARA Title III,
also known as the Emergency Planning and Community Right-to-Know Act
(EPCRA).
The CERCLA hazardous substance release reporting regulations (40 CFR
Part 302) direct the person in charge of a facility to report to the National
Response Center (NRC) any environmental release of a hazardous substance
which equals,or exceeds a reportable quantity. Reportable quantities are
listed in 40 CFR section 302.4. A release report may trigger a response by
EPA or by one or more federal or state emergency response authorities.
EPA implements hazardous substance responses according to procedures
outlined in the National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) (40 CFR Part 300). The NCP includes provisions for cleanups.
The National Priorities List (NPL) currently includes approximately 1,300
sites. Both EPA .and states can act at other sites; however, EPA provides
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responsible parties the opportunity to conduct cleanups and encourages
community involvement throughout the Superfund response process.
EPA's RCRA, Superfund and EPCRA Hotline, at (800) 424-9346, answers
questions and references guidance pertaining to the Superfund program.
Documents and resources can be obtained from the hotline's homepage at
http://www.epa.gov/epaoswer/hotline. The Superfund Hotline operates
weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays.
Emergency Planning and Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title III), a statute designed to improve
community access to information about chemical hazards and to facilitate the
development of chemical emergency response plans by state and local
governments. Under EPCRA, states establish State Emergency Response
Commissions (SERCs), responsible for coordinating certain emergency
response activities and for appointing Local Emergency Planning Committees
(LEPCs). EPCRA and the EPCRA regulations (40 CFR Parts 350-372)
establish four types of reporting obligations for facilities which store or
manage specified chemicals:
EPCRA section 302 requires facilities to notify the SERC and LEPC
of the presence of any extremely hazardous substance at the facility
in an amount in excess of the established threshold planning quantity.
The list of extremely hazardous substances and their threshold
planning quantities is found at 40 CFR Part 355, Appendices A and
B.
• EPCRA section 303 requires that each LEPC develop an emergency
plan. The plan must contain (but is not limited to) the identification
of facilities within the planning district, likely routes for transporting
extremely hazardous substances, a description of the methods and
procedures to be followed by facility owners and operators, and the
designation of community and facility emergency response
coordinators.
EPCRA section 304 requires the facility to notify the SERC and the
LEPC in the event of a release exceeding the reportable quantity of a
CERCLA hazardous substance (defined at 40 CFR Part 302) or an
EPCRA extremely hazardous substance.
• EPCRA sections 311 and 312 require a facility at which a hazardous
- chemical, as defined by the Occupational Safety and Health Act, is
present in an amount exceeding a specified threshold to submit to the
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SERC, LEPC and local fire department material safety data sheets
(MSDSs) or lists of MSDSs and hazardous chemical inventory forms
(also known as Tier I and II forms). This information helps the local
government respond in the event of a spill or release of the chemical.
EPCRA section 313 requires certain covered facilities, including SIC
codes 20 through 39 and others, which have ten or more employees,
and which manufacture, process, or use specified chemicals in
amounts greater than threshold quantities, to submit an annual toxic
chemical release report. This report, commonly known as the Form
R, covers releases and transfers of toxic chemicals to various facilities
and environmental media. EPA maintains the data reported in a
publically accessible database known as the Toxics Release Inventory
(TRI).
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
EPA'sRCRA, Superfund, and EPCRA Hotline, at (800) 535-0202, answers
questions and distributes guidance regarding the emergency planning and
community right-to-know regulations. Documents and resources can be
obtained from the . hotline's homepage at
http://www.epa.gov/epaoswer/hotline. The EPCRA Hotline operates
weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments are designed to "protect and
enhance the nation's air resources so as to promote the public health and
welfare and the productive capacity of the population." The CAA consists
of six sections, known as Titles, which direct EPA to establish national
standards for ambient air quality and for EPA and the states to implement,
maintain, and enforce these standards through a variety of mechanisms.
Under the CAA, many facilities are required to obtain operating permits that
consolidate their air emission requirements. State and local governments
oversee, manage, and enforce many of the requirements of the CAA. CAA
regulations appear at 40 CFR Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national ambient air
quality standards (NAAQSs) to limit levels of "criteriapollutants," including
carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur
dioxide. Geographic areas that meet NAAQSs for a given pollutant are
designated as attainment areas; those that do not meet NAAQSs are
designated as non-attainment areas. Under section 110 and other provisions
of the CAA, each state must develop a State Implementation Plan (SIP) to
identify sources of air pollution and to determine what reductions are required
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to meet federal air quality standards. Revised NAAQSs for particulates and
ozone were finalized in 1997. However, these revised NAAQSs are currently
being challenged before the U.S. Supreme Court.
Title I also authorizes EPA to establish New Source Performance Standards
(NSPS), which are nationally uniform emission standards for new and
modified stationary sources falling within particular industrial categories.
The NSPSs are based on the pollution control technology available to that
category of industrial source (see 40 CFR Part 60).
Under Title I, EPA establishes and enforces National Emission Standards for
Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
toward controlling specific hazardous air pollutants (HAPs). Section 112(c)
of the CAA further directs EPA to develop a list of sources that emit any of
188 HAPs andto develop regulations for these categories of sources. To date
EPA has listed 185 source categories and developed a schedule for the
establishment of emission standards. The emission standards are being
developed for both new and existing sources based on "maximum achievable
control technology" (MACT). The MACT is defined as the control
technology achieving the maximum degree of reduction in the emission of the
HAPs, taking into account cost and other factors.
Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
and planes. Reformulated gasoline, automobile pollution control devices,
and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
uses to regulate mobile air emission sources.
Title IV-A establishes a sulfur dioxide and nitrogen oxides emissions
program designed to reduce the formation of acid rain. Reduction of sulfur
dioxide releases will be obtained by granting to certain sources limited
emissions allowances that are set below previous levels of sulfur dioxide
releases.
Title V of the CAA establishes an operating permit program for all "major
sources" (and certain other sources) regulated under the CAA. One purpose
of the operating permit is to include in a single document all air emissions
requirements that apply to a given facility. States have developed the permit
programs in accordance with guidance and regulations from EPA. Once a
state program is approved by EPA, permits are issued and monitored by that
state.
Title VI of the CAA is intended to protect stratospheric ozone by phasing out
the manufacture of ozone-depleting chemicals and restrict their usage and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), were phased out (except for essential uses) in
1996. Methyl bromide, a common pesticide, has been identified as a
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significant stratospheric ozone depleting chemical. The production and
importation of methyl bromide, therefore, is currently being phased out in the
United States and internationally. As specified in the Federal Register of June
1,1999 (Volume 64, Number 104) and in 40 CFR Part 82, methyl bromide
production and importation will be reduced from 1991 levels by 25% in
1999, by 50% in 2001, by 70% in 2003, and completely phased out by 2005.
Some uses of methyl bromide, such the production, importation, and
consumption of methyl bromide to fumigate commodities entering or leaving
the United States or any state (or political subdivision thereof) for purposes
of compliance with Animal and Plant Health Inspection Service requirements
or with any international, federal, state, or local sanitation or food protection
standard, will be exempt from this rule. After 2005, exceptions may also be
ma'de for critical agricultural uses. The United States EPA and the United
Nations Environment Programme have identified alternatives to using methyl
bromide in agriculture. Information on the methyl bromide phase-out,
including alternatives, can be found at the EPA Methyl Bromide Phase-Out
Web Site: (http://www.epa.gov/docs/ozone/mbr/mbrqa.html).
EPA's Clean Air Technology Center, at (919) 541-0800 and at the Center's
homepage at http://www.epa.gov/ttn/catc, provides general assistance and
information on CAA standards. The Stratospheric Ozone Information
Hotline, at (800) 296-1996 and at http://www.epa.gov/ozone, provides
general information about regulations promulgated under Title VI of the
CAA; EPA's EPCRA Hotline, at (800) 535-0202 and at
http://www.epa.gov/epaoswer/hotline, answers questions about accidental
release prevention under CAA section 112(r); and information on air toxics
can be accessed through the Unified Air Toxics website at
http://www.epa.gov/ttn/uatw. In addition, the Clean Air Technology Center's
website includes recent CAA rules, EPA guidance documents, and updates
of EPA activities.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to create
a regulatory framework to collect data on chemicals in order to evaluate,
assess, mitigate, and control risks which may be posed by their manufacture,
processing, and use. TSCA provides a variety of control methods to prevent
chemicals from posing unreasonable risk. It is important to note that
pesticides as defined in FIFRA are not included in the definition of a
"chemical substance" when manufactured, processed, or distributed in
commerce for use as a pesticide.
TSCA standards may apply at any point during a chemical's life cycle. Under
TSCA section 5, EPA established an inventory of chemical substances. If a
chemical substance is not already on the inventory, and has not been excluded
by TSCA, a premanufacture notice (PMN) must be submitted to EPA prior
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to manufacture or import. The PMN must identify the chemical and provide
available information on health and environmental effects. If available data
are not sufficient to evaluate the chemical's effects, EPA can impose
restrictions pending the development of information on its health and
environmental effects. EPA can also restrict significant new uses of
chemicals based upon factors such as the projected volume and use of the
chemical.
Under TSCA section 6, EPA can ban the manufacture or distribution in
commerce, limit the use, require labeling, or place other restrictions on
chemicals that pose unreasonable risks. Among the chemicals EPA regulates
under section 6 authority are asbestos, chlorofluorocarbons (CFCs), lead, and
polychlorinated biphenyls (PCBs).
Under TSCA section 8(e), EPA requires the producers and importers (and
others) of chemicals to report information on a chemical's production, use,
exposure, and risks. Companies producing and importing chemicals can be
required to report unpublished health and safety studies on listed chemicals
and to collect and record any allegations of adverse reactions or any
information indicating that a substance may pose a substantial risk to humans
or the environment.
EPA's TSCA Assistance Information Service, at 202 554-1404, answers
questions and distributes guidance pertaining to Toxic Substances Control
Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST,
excluding federal holidays.
Coastal Zone Management Act
The Coastal Zone Management Act (CZMA) encourages states/tribes to
preserve, protect, develop, and where possible, restore or enhance valuable
natural coastal resources such as wetlands, floodplains, estuaries, beaches,
dunes, barrier islands, and coral reefs, as well as the fish and wildlife using
those habitats. It includes areas bordering the Atlantic, Pacific, and Arctic
Oceans, Gulf of Mexico, Long Island Sound, and Great Lakes. A unique
feature of this law is that participation by states/tribes is voluntary.
In the Coastal Zone Management Act Reauthorization Amendments
(CZARA) of 1990, Congress identified nonpoint source pollution as a major
factor in the continuing degradation of coastal waters. Congress also
recognized that effective solutions to nonpoint source pollution could be
implemented at the state/tribe and local levels. In CZARA, Congress added
section 6217 (16 U.S.C. section 1455b), which calls upon states/tribes with
federally-approved coastal zone management programs to develop and
implement coastal nonpoint pollution control programs. The section 6217
program is administered at the federal level jointly by EPA and the National
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Oceanic and Atmospheric Agency (NOAA).
Section 6217r(g) called for EPA, in consultation with other agencies, to
develop guidance on "management measures" for sources of nonpoint source
pollution in coastal waters. Under section 6217, EPA is responsible for
developing technical guidance to assist states/tribes in designing coastal
nonpoint pollution control programs. On January 19, 1993, EPA issued its
Guidance Specifying Management Measures For Sources of Nonpoint
Pollution in Coastal Waters, which addresses five major source categories of
nonpoint pollution: (1) urban runoff, (2) agriculture runoff, (3) forestry
runoff, (4) marinas and recreational boating, and (5) hydromodification.
Additional information on coastal zone management may be obtained from
EPA's Office of Wetlands, Oceans, and Watersheds at
http://www.epa.gov/owow or from the Watershed Information Network at
http://www.epa.gov/win., The NOAA website at
http://www. nos. noaa. gov/ocrm/czm/also contains additional information on
coastal zone management.
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VLB. Industry Specific Requirements
The agricultural chemical industry is affected by several major federal
environmental statutes. In addition, the industry is subject to numerous laws
and regulations from state and local governments designed to protect health,
safety, and the environment. A summary of the major federal regulations
affecting the agricultural chemical industry follows.
Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
; , . Every regulation promulgated under FIFRA affects the agricultural chemical
industry in some way. The FIFRA regulations are found in 40 CFR Parts 152
through 186. Each part and its title are listed below.
Part 152 - Pesticide Registration and Classification Procedures
Part 153 - Registration Policies and Interpretations
Part 154 - Special Review Procedures
Part 155 - Registration Standards
Part 156 - Labeling Requirements for Pesticides and Devices
Part 157 - Packaging Requirements for Pesticides and Devices
Part 158 - Data Requirements for Registration
Part 160 - Good Laboratory Practice Standards
Part 162 - State Registration of Pesticide Products
Part 163 - Certification of Usefulness of Pesticide Chemicals
Part 164 - Rules of Practice Governing Hearings, Under FIFRA,
Arising from Refusals to Register, Cancellations of
Registrations, Changes of Classifications, Suspensions of
Registrations and Other Hearings Called Pursuant to
section 6 of the Act
Part 166 - Exemption of Federal and State Agencies for Use of
Pesticides Under Emergency Conditions
Part 167 - Registration of Pesticide and Active Ingredient Producing
Establishments, Submission of Pesticide Reports
Part 168 - Statements of Enforcement Policies and Interpretations
Part 169 - Books and Records of Pesticide Production and
Distribution
Part 170 - Worker Protection Standards
Part 171 - Certification of Pesticide Applicators
Part 172 - Experimental Use Permits
Part 173 - Procedures Governing the Rescission of State Primary
Enforcement Responsibility for Pesticide Use Violations
Part 177 - Issuance of Food Additive Regulations
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Part 178 - Objections and Requests for Hearings
Part 179 - Formal Evidentiary Public Hearing
Part 180 - Tolerances and Exemptions from Tolerances for Pesticide
Chemicals in or on Raw Agricultural Commodities
Part 185 - Tolerances for Pesticides in Food
Part 186- Pesticides in Animal Feed
Please refer to the general discussion of FIFRA in Section VI. A for additional
requirements not discussed below.
Product Registration Data Requirements
EPA requires the citation or submission of extensive environmental, health,
and/or safety data during the registration application process. The categories
of data required include the product's chemistry; environmental fate; residue
chemistry, hazards to humans, domestic animals, and nontarget organisms;
spray drift characteristics; reentry protection requirements; and performance
(40 CFR Part 158). Under the "product chemistry" category, applicants must
supply technical information describing the product's active and inert
ingredients, manufacturing or formulating processes and physical and
chemical characteristics. Data from "environmental fate" studies are used to
assess the effects of pesticide residues on the environment, including its
toxicity to people through consumption or exposure to applied areas and its
effect on nontarget organisms and their habitat. Residue chemistry
information includes the expected frequency, amounts, and time of
application, and test results of residue remaining on treated food or feed.
Information under "hazards to humans, domestic animals, and non-target
organisms" includes specific test data assessing acute, subchronic, and
chronic toxicity. All studies required to be submitted must satisfy Good
Laboratory Practice (GLP) regulations (40 CFR Part 160). Guidelines for
studies of product chemistry, residue chemistry, environmental chemistry,
hazard evaluation and occupational and residential exposure can be found in
40 CFR Part 158.
Registration of Establishments
Any person producing a pesticide or device, except a custom blender,4 is
subject to section 7 and 40 CFR. Part 167; and is required to register his
A custom blender means any establishment which provides the service of mixing pesticides to a customer's
specifications, usually a pesticide(s)-fertilizer(s), pesticide-pesticide, or a pesticide animal feed mixture, when: (1)
The blend is prepared to the order of the customer and is not held in inventory by the blender; (2) the blend is to be
used on the customer's property (including leased or rented property); (3) the pesticide(s) used in the blend bears
end-use labeling directions which do not prohibit use of the product in such a blend; (4) the blend is prepared from
registered pesticides; (b) the blend is delivered to the end-user along with a copy of the end-use labeling of each
pesticide used in the blend and a statement specifying the composition of mixture; and (6) no other pesticide
production activity is performed at the establishment.
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establishment with EPA prior to beginning production. Foreign
establishments also must register with EPA if they produce a pesticidal
product for import to the United States. Establishments must be registered
with EPA if they intend that a substance produced will be used as an active
ingredient of a pesticide or if they have actual or constructive notice that the
substance will be used as an active ingredient. If a pesticide is produced for
export, whether registered or unregistered, or is produced under an
experimental use permit, the producing establishment must be registered.
In order to register an establishment with EPA, contact the EPA Regional
office where the establishment is located, or for a foreign establishment, the
Washington, DC EPA office. The following information must be submitted
on EPA Form 3540-1 when registering an establishment: (1) the name and
address of the company; (2) the type of ownership; and (3) the name and
address of each producing establishment for which registration is sought.
Any changes to the information provided must be submitted to EPA within
thirty days after such changes occur. Upon receiving a complete application,
EPA will assign a registration number for each listed establishment. This
number must appear on the label.
Establishment Reporting Requirements
Under section 7(c)and 40 CFR. section 167.85, each registered pesticide
producing establishment must submit an annual production report to EPA by
March 1 of each year. Domestic establishments submit their report to the
EPA regional office where the company headquarters is located. Foreign
establishment production reports are submitted to the Washington, DC EPA
office. Custom blenders are exempt from this requirement.
The report must cover any pesticide, active ingredient, or device produced.
The report, to be submitted on specific EPA forms, includes the following
information: (1) the name and address of the establishment; (2) the amount
of each pesticide produced, repackaged, or relabeled in the past year; (3) the
amount of each pesticide sold, distributed, or exported in the past year; and
(4) the amount of the pesticide estimated to be produced, repackaged, or
relabeled in the current year. Foreign establishments only are required to
submit a report on pesticides imported into the United States.
Maintenance of Records
All producers of pesticides, devices, or active ingredients used in producing
any pesticide must maintain records concerning the production and shipment
of each pesticide under 40 CFR Part 169. These records are independent of
other required records, including in-plant maintenance, extermination, or
sanitation programs. Each establishment must maintain these records for two
years. In addition, records on disposal methods must be maintained for 20
years, as well as authorized human trials. Records containing research data
must be maintained as long as the registration is valid and the producer is in
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business. All required records must be available if requested by an inspector.
Prior Informed Consent
As part of its participation in a voluntary international program known as the
Prior Informed Consent procedure, EPA prepares the following lists of
pesticides that are suspended, canceled or severely restricted. These lists
were last updated by EPA in August of 1997.
A "Suspended or Canceled" pesticide is defined as a pesticide for which all
registered uses have been prohibited by final government action, or for which
all requests for registration or equivalent action for all uses have, for health
or environmental reasons, not been granted.
• Suspended or Canceled
1. aldrin
2. benzene hexachloride [BHC] (voluntary cancellation)
3. 2,3,4,5-Bis(2-burylene)tetrahydro-2-furaldehyde [Repellent-11]
4. bromoxynil butyrate (voluntary cancellation)
5. cadmium compounds (voluntary cancellation)
6. calcium arsenate (voluntary cancellation)
7. captafol (voluntary cancellation)
8. carbon tetrachloride
9. chloranil (voluntary cancellation)
10. chlordane
11. chlordimeform (voluntary cancellation)
12. chlorinated camphene [Toxaphene] (voluntary cancellation)
13. chlorobenzilate (voluntary cancellation)
14. chloromethoxypropylmercuric acetate [CPMA]
15. copper arsenate (voluntary cancellation)
16. cyhexatin (voluntary cancellation)
17. DBCP
18. decachlorooctahydro-1,3,4-metheno-2H-cyclobuta(cd) pentalen-2-
onefchlordecone]
19. DDT
20. dieldrin
21. dinoseb and salts
22. Di(phenylmercury)dodecenylsuccinate [PMDS] (voluntary
cancellation)
23. EDB
24. endrin (voluntary cancellation)
25. EPN (voluntary cancellation)
26. ethyl hexyleneglycol [6-12] (voluntary cancellation)
27. hexachlorobenzene [HCB] (voluntary cancellation)
28. lead arsenate (voluntary cancellation)
29. leptophos (Never received initial registration)
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30. mercurous chloride
31. mercuric chloride
32. mevinphos
33. mirex (voluntary cancellation)
34. monocrotophos (voluntary cancellation)
35. nitrofen (TOK) (voluntary cancellation)
36. OMPA (octamethylpyrophosphoramide)
37. phenylmercury acetate [PMA]
38. phenylmercuric oleate [PMO] (voluntary cancellation)
39. potassium 2,4,5-trichlorophenate [2,4,5-TCP] '
40. pyriminil [Vacor] (voluntary cancellation)
41. safrole (voluntary cancellation)
42. silvex
43. sodium arsenite
44. TDE (voluntary cancellation)
45. Terpene polychlorinates [Strobane] (voluntary cancellation)
46. thallium sulfate
47. 2,4,5-Trichlorophenoxyacetic acid [2,4,5-T]
48. vinyl chloride
A "Severely Restricted" pesticide means a pesticide for which virtually all
registered uses have been prohibited by final government regulatory action,
but for which certain specific registered use or uses remain authorized.
• Severely Restricted
1. arsenic trioxide
2. azinphos methyl
3. carbofuran (voluntary cancellation)
4. daminozide (voluntary cancellation)
5. heptachlor
6. methyl parathion
7. sodium arsenate
8. tributyltin compounds
Federal Food, Drug, and Cosmetics Act
Under the Federal Food, Drug, and Cosmetics Act (FFDCA), EPA sets
tolerances for pesticide residues in food. This authority originally belonged
to the Food and Drug Administration (FDA), but was transferred when EPA
was formed in 1970. FDA still has responsibility for enforcing compliance
with the tolerances. An agricultural product is deemed unsafe under the
FFDCA if it contains pesticide residues above the tolerance level established
by EPA or if there is no tolerance, unless it is exempt from the requirement
for tolerances.
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The FFDCA also contains the Delaney Clause that bars the establishment of
food additive regulations covering substances that induce cancer in humans
or animals. Prior to the Food Quality Protection Act of 1996, this provision
applied to certain pesticide residues in processed food. With the 1996
amendments, pesticide residues are now governed by a single safety clause
set forth in section 408.
Toxic Substances Control Act (TSCA)
TSCA gives EPA comprehensive authority to regulate any chemical
substance whose manufacture, processing, distribution in commerce, use, or
disposal may present an unreasonable risk of injury to health or the
environment. EPA keeps an inventory of existing chemicals regulated under
TSCA (TSCA section 8(b)). Certain chemicals are specifically excluded
from the TSCA inventory, such as pesticides, as defined when manufactured,
processed, or distributed in commerce for use as a pesticide under FIFRA (40
CFR section 710.2(h)(2)). However, if a chemical has multiple uses, those
uses not subject to FIFRA are regulated by TSCA. In addition, certain
mixtures of chemicals are exempt from TSCA (40 CFR section 710.2(h)(l))
(Landfair, 1993).
Four sections are of primary importance to the remainder of the agricultural
chemical industry. Section 5 mandates that chemical companies submit to
EPA pre-manufacture notices that provide information on health and
environmental effects for each new product and test existing products for
these effects (40 CFR Part 720). Over 20,0.00 premanufacture notices have
been filed. Section 4 authorizes EPA to require testing of certain substances
(40 CFR Part 790). Section 6 gives EPA the authority to prohibit, limit, or
ban the manufacture, process, and usage of chemicals (40 CFR Part 750).
Among the chemicals EPA regulates under section 6 are asbestos,
chlorofluorocarbons (CFCs), and polychlorinated biphenyls (PCBs). For
certain chemicals; TSCA section 8 also imposes record-keeping and reporting
requirements including substantial risk notification; record-keeping for data
relative to adverse reactions; and periodic updates to the TSCA Inventory.
Resource Conservation and Recovery Act (RCRA)
The Resource Conservation and Recovery Act (RCRA) was enacted in 1976
to address problems related to hazardous and solid waste management.
RCRA gives EPA the authority to establish a list of solid and hazardous
wastes and to establish standards and regulations for the treatment, storage,
and disposal of these wastes. Regulations in Subtitle C of RCRA address the
identification, generation, transportation, treatment, storage, and disposal of
hazardous wastes. These regulations are found in 40 CFR Part 124 and CFR
Parts 260-279. Under RCRA, persons who generate waste must determine
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whether the waste is defined as solid waste or hazardous waste. Solid wastes
are considered hazardous wastes if they are listed by EPA as hazardous or if
they exhibit characteristics of a hazardous waste: toxicity, ignitability,
corrosivity, or reactivity.
Products, intermediates, and off-specification products potentially generated
at agricultural chemical facilities that are considered hazardous wastes are
listed in 40 CFR Part 261. Some of the handling and treatment requirements
for RCRA hazardous waste generators are covered under 40 CFR Part 262
and include the following: determining what constitutes a RCRA hazardous
waste (Subpart A); manifesting (Subpart B); packaging, labeling, and
accumulation time limits (Subpart C); and record keeping and reporting
(Subpart D).
Many agricultural chemical facilities store some hazardous wastes at the
facility beyond the accumulation time limits available to generators (e.g., 90
or 180 days). Such facilities are required to have a RCRA treatment, storage,
and disposal facility (TSDF) permit (40 CFRPart 262.34). Some agricultural
chemical facilities are considered TSDF facilities and are subj ect to a number
of regulations, including but not limited to those covered under 40 CFR Part
264: contingency plans and emergency procedures (40 CFR Part 264 Subpart
D); manifesting, record keeping, and reporting (40 CFR Part 264 Subpart E);
use and management of containers (40 CFR Part 264 Subpart I); tank systems
(40 CFR Part 264 Subpart J); surface impoundments (40 CFR Part 264
Subpart K); land treatment (40 CFR Part 264 Subpart M); corrective action
of hazardous waste releases (40 CFR Part 264 Subpart S); air emissions
standards for process vents of processes that process or generate hazardous
wastes (40 CFR Part 264 Subpart AA); emissions standards for leaks in
hazardous waste handling equipment (40 CFR Part 264 Subpart BB); and
emissions standards for containers, tanks, and surface impoundments that
contain hazardous wastes (40 CFR Part 264 Subpart CC).
Many agricultural chemical facilities are also subject to the underground
storage tank (UST) program (40 CFR Part 280). The UST regulations apply
to facilities that store either petroleum products or hazardous substances
(except hazardous waste) identified under the Comprehensive Environmental
Response, Compensation, and Liability Act. UST regulations address design
standards, leak detection, operating practices, response to releases, financial
responsibility for releases, and closure standards.
A number of RCRA wastes have been prohibited from land disposal unless
treated to meet specific standards under the RCRA Land Disposal Restriction
(LDR) program. The wastes covered by the RCRA LDRs are listed in 40
CFR Part 268 Subpart C and include a number of wastes that could
potentially be generated at agricultural chemical facilities. Standards for the
treatment and storage of restricted wastes are described in Subparts D and E,
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respectively.
The LDRs also apply to the use of fertilizers containing hazardous wastes.
Therefore, fertilizers containing hazardous wastes that do not meet the
applicable land disposal treatment standards cannot be spread on the land,
with some exceptions. Specific exemptions to the use of certain recycled
materials and hazardous wastes in fertilizers have been provided in 40 CFR
Part 266, Subpart C - Recycled Materials Used in a Manner Constituting
Disposal. Subpart C states that products containing recyclable materials are
not subject to regulation under RCRA if the recyclables are physically
inseparable from the product or if they meet the standards of 40 CFR Part
268, Subpart D "for each recyclable material (i.e., hazardous waste) that they
contain." These standards include limits on heavy metals. Subpart C also
states that zinc-containing fertilizers using hazardous waste K061 (emission
control dust/sludge from the primary production of steel in electric furnaces)
which is listed as hazardous due to its hexavalent chromium, lead, and
cadmium content, are not subject to the land disposal requirements.
Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
The Comprehensive Environmental Response, Compensation, and Liability
Act of 1980 (CERCLA) and the Superfund Amendments andReauthorization
Act of 1986 (SARA) provide the basic legal framework for the federal
"Superfund" program to clean up abandoned hazardous waste sites (40 CFR
Part 300 et seq.). The 1986 SARA legislation extended CERCLA taxes for
five years and adopted a new broad-based corporate environmental tax,
applicable to the allied chemicals (SIC 28) industry, which includes the
agricultural chemical industry. In 1990, Congress passed a simple
reauthorization that did not substantially change the law but extended the
program authority until 1994 and the taxing authority until the end of 1995.
A comprehensive reauthorization was considered in 1994, but not passed.
Since the expiration of the taxing authority on December 31,1995, taxes for
Superfund have been temporarily suspended. The taxes can only be
reinstated by reauthorization of Superfund or an omnibus reconciliation act
which could specifically reauthorize taxing authority. The allied chemical
industry paid about $300 million a year in Superfund chemical feedstock
taxes. Joint and several liability generally requires Potentially Responsible
Parties (PRPs) to perform or pay for their fair share of cleanup costs.
Title III of the 1986 SARA amendments (also known as Emergency Response
and Community Right-to-Know Act, EPCRA) requires all manufacturing
facilities, including agricultural chemical facilities, to report annual
information about stored toxic substances, as well as release of these
substances into the environment, to local and state governments and to the
public. This is known as the Toxic Release Inventory (TRI). EPCRA also
establishes requirements for federal, state, and local governments regarding
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emergency planning. In 1994, over 300 more chemicals were added to the
list of chemicals for which reporting is required.
Clean Air Act (CAA)
The original CAA authorized EPA to set limits on agricultural chemical
facility emissions. The new source performance standards (NSPS) for
fertilizer manufacturers can be found in 40 CFR Part 60:
Subpart G - Standards of Performance for Nitric Acid Plants
(40 CFR section 60.70 - 60.74)
Subpart T - Standards of Performance for the Phosphate Fertilizer
Industry: Wet Process Phosphoric Acid Plants
(40 CFR section 60.200 - 60.204)
Subpart U - Standards of Performance for the Phosphate Fertilizer
Industry: Superphosphoric Acid Plants
(40 CFR section 60.210 - 60.214)
Subpart V - Standards of Performance for the Phosphate Fertilizer
Industry: Diammonium Phosphate Plants
(40 CFR section 60.220 - 60.224)
Subpart W -. Standards of Performance for the Phosphate Fertilizer
Industry: Triple Superphosphate Plants
(40 CFR section 60.230 - 60.234)
Subpart X -. Standards of Performance for the Phosphate Fertilizer
Industry: Granular Triple Superphosphate Storage
Facilities (40 CFR section 60.240 - 60.244)
These standards primarily consist of emission and monitoring standards for
nitrogen oxides (Nitric Acid Plants) and fluorides (Phosphatic Fertilizer
Industry).
The Clean Air Act Amendments of 1990 set National Emission Standards for
Hazardous Air Pollutants (NESHAP) from industrial sources for 41
hazardous air pollutants to be met by 1995 and for 148 other hazardous air
pollutants to be reached by 2003. National emission standards for new and
existing major sources in phosphoric acid manufacturing, phosphate
fertilizers production and pesticide active ingredient production are listed in
40 CFR Parts 9 and 63. 40 CFR Parts 61 and 63 contains several provisions
dealing with emissions sources potentially found at an agricultural chemical
facility (e.g. equipment leaks, tanks, surface impoundments, separators, and
waste treatment operations) may affect the agricultural chemical industry. A
number of the chemicals used and produced at agricultural chemical
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manufacturing and formulating facilities are hazardous air pollutants under
CAA.
Under section 112(r) of CAA, owners and operators of stationary sources
who produce, process, handle, or store substances listed under CAA section
112(r)(3) or any other extremely hazardous substance have a "general duty"
to initiate specific activities to prevent and mitigate accidental releases. Since
the general duty requirements apply to stationary sources regardless of the
quantity of substances managed at the facility, many agricultural chemical
manufacturing and formulating facilities are subject. Activities such as
identifying hazards which may result from accidental releases using
appropriate hazard assessment techniques; designing, maintaining and
operating a safe facility; and minimizing the consequences of accidental
releases if they occur are considered essential activities to satisfy the general
duty requirements. These statutory requirements have been in affect since the
passage of the Clean Air Act in 1990. Although there is no list of "extremely
hazardous substances," EPA's Chemical Emergency Preparedness and
Prevention Office provides some guidance at its website:
http://www.epa.gov/swercepp.html.
Also under section! 12(r), EPA was required to develop a list of at least 100
substances that, in the event of an accidental release, could cause death,
injury, or serious adverse effects to human health or the environment. The
list promulgated by EPA is contained in 40 CFR section 68.130 and includes
acutely toxic chemicals, flammable gases and volatile flammable liquids.
Under section 112(r)(7), facilities handling more than a threshold quantity
(ranging from 500 to 20,000 pounds) of these substances are subject to
chemical accident prevention provisions including the development and
implementation of a risk management program (40 CFR sections 68.150-
68.22Q). The requirements in 40 CFR Part 68 begin to go into effect in June
1999. Many of the chemicals on the 112(r) list are commonly handled by
agricultural chemical manufacturers and formulators in quantities greater than
the threshold values. Ammonia held by farmers for use as an agricultural
nutrient is exempt from the chemical accident prevention provisions.
Standards in 40 CFR Part 61 Subpart R - National Emission Standards for
Radon Emissions from Phosphogypsum Stacks (40 CFR sections 61.200 -
61.210) deal specifically with the phosphatic fertilizer industry. The
standards require monitoring and reporting of radon-222 emissions from the
stacks and sets limits on the amounts of radon-222 that can be emitted into
the air. EPA has also set standards for the maximum concentration of
radium-226 allowed in phosphogypsum removed from stacks for use in
agriculture.
Clean Water Act (CWA)
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The Clean Water Act, first passed in 1972 and amended in 1977 and 1987,
gives EPA the authority to regulate effluents from sewage treatment works,
chemical plants, and other industrial sources into waters. The act sets
standards for treatment of wastes for both direct and indirect (to a Publicly.
Owned Treatment Works (POTW)) discharges. EPA has set effluent
guidelines for both the fertilizer manufacturing and formulating, and pesticide
formulating, packaging and repackaging point source categories. The
implementation of the guidelines is left primarily to the states who issue
National Pollutant Discharge Elimination System (NPDES) permits for each
facility (EPA has authorized 43 'states to operate the NPDES program).
Effluent guidelines specific to the fertilizer manufacturing and formulating
point source category are contained in 40 CFR Part 418 and are divided into
product specific effluent guidelines as follows:
Subpart A - Phosphates (40 CFR section 418.10-418.17)
Subpart B - Ammonia (40 CFR section 418.20 - 418.27)
Subpart C- Urea (40 CFR section 418.30-418.36)
Subpart D - Ammonium Nitrate (40 CFR section 418.40 - 418.46)
Subpart E - Nitric Acid (40 CFR section 418.50 - 418.56)
Subpart F - Ammonium Sulfate (40 CFR section 418.60 - 418.67)
Subpart G - Mixed and Blend Fertilizer Production
(40 CFR section 418.70-418.77)
In 1997, revised effluent guidelines were finalized for the Pesticide
Formulating, Packaging and Repackaging Subcategory. These regulations
replace the effluent guidelines established in 1978 for the Pesticide
Formulating and Packaging Subcategory. The revised guidelines are
contained in 40 CFR Part 455 and are divided into the following
subcategories:
Subpart C - Pesticide Chemicals Formulating and Packaging
Subcategory
Subpart E - Repackaging of Agricultural Pesticides Performed at
Refilling Establishments
Each Subpart consists of effluent standards representing the amount of
effluent reduction possible by using either best practicable control
technologies (BPT), best conventional pollution technologies (BCT), or best
available technologies (BAT). The states and EPA give effect to these
standards through NPDES permits that they issue to direct dischargers. BCT
standards limit the discharge of conventional pollutants, while BPT and BAT
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standards represent successive levels of control of priority pollutants and
non-conventional pollutants.
For Subcategory C, EPA established effluent limitations and pretreatment
standards which allow each facility a choice of meeting a zero discharge
limitation or to comply with a pollution prevention alternative that authorizes
the discharge of some pesticide active ingredients (AIs) and priority
pollutants after various pollution prevention practices are followed and
treatment is conducted as needed. For Subcategory E, EPA has established
a zero discharge limitation and pretreatment standard.
The Storm Water Rule (40 CFR section 122.26) requires fertilizer
manufacturing and formulating and pesticide formulating facilities
discharging storm water associated with industrial activities (40 CFR section
122.26 (b)(14)(ii)) to apply for NPDES permits for those discharges.
Under 40 CFR 503 Subpart B - Land Application, EPA regulates the land
application of sewerage treatment sludge, which includes fertilizers derived
from sewerage treatment sludge. Subpart B regulations include specific
limitations on heavy metal content, as well as general operational and
management standards.
VI.C. State Regulation of Pesticides
All states have their own pesticide laws and many states have their own
pesticide registration requirements. States have primary use enforcement
authority if EPA has determined that the state has adequate pesticide use laws
and has adopted adequate procedures to enforce those laws. The EPA may
enter into a cooperative agreement with a state to carry out enforcement of
state laws and train and certify applicators. The FIFRA allows states to
administer their own EP A-approved applicator certifications program. Also,
each state is allowed to regulate the sale and use of pesticides as long as the
regulations are at least as stringent as EPA's and the regulations do not
conflict or differ from EPA's labeling and packaging restrictions.
States typically require that fertilizer products be registered with the state and
that claims made on fertilizer labels can be substantiated. States also regulate
the efficacy of fertilizers through labeling requirements. State fertilizer
labeling requirements typically require that the label indicate the product
name, the brand and grade, the percentage of each nutrient (nitrogen,
available phosphate, potassium, etc.), and the name and address of the
registrant. Some states also require that the label indicate materials from
which the nutrients are derived.
Additional information on specific state requirements can be obtained from
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the Association of American Pesticide Control Officials, Inc. (AAPCO) at:
http://aapco.ceris.purdue.edu/index.html. This website contains a list of
state pesticide control officials that includes contact information.
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VI.D. Pending and Proposed Regulatory Requirements
FIFRA
Registration
In order to reduce the potential for groundwater contamination from
certain pesticides, EPA proposed the Ground Water Pesticide
Management Plan Rule in June of 1996 (61 FR 33259). EPA is
proposing to restrict the use of certain pesticides by providing states
and tribes with the flexibility to protect the ground water in the most
appropriate way for local conditions, through the development and
use of Pesticide Management Plans (PMPs). When finalized, the
regulations will likely give states and tribes the authority to develop
management plans that specify risk reduction measures for the
following four pesticides: atrazine, alachlor, simazine, and
metolachlor. Without EPA-approved plans, use of these chemicals
would be prohibited. A final rule is expected to be published in late
2000. (Contact: Arty Williams, United States EPA Office of
Prevention, Pesticides and Toxic Substances, 703-305-5239)
In response to the Food Quality Protection Act of 1996, EPA is
planning to propose revisions to antimicrobial registration and
classification procedures (40 CFR Part 152) that will reduce to the
extent possible the review time for antimicrobial pesticides.
Revisions to labeling requirements (40 CFR Part 156) and data
requirements for antimicrobial registration (40 CFR Part 158) are
also being proposed. The revisions are expected to be released in
early 2001. This regulation would also implement some general
provisions of FIFRA that pertain to all pesticides, including labeling
requirements and notification procedures. (Contact: Jean Frane,
United States EPA Office of Prevention, Pesticides, and Toxic
Substances, 703-305-5944 and Paul Parsons, United States EPA
Office of Prevention, Pesticides, and Toxic Substances, 703-308-
9073)
In order to evaluate the registrability of pesticide products, EPA is
expected to propose revisions to the data requirements for FIFRA
registration (40 CFR Part 158). These revisions would clarify all data
requirements to reflect current practice and are expected to be
published in 2001. (Contact: Jean Frane, United States EPA Office of
Prevention, Pesticides, and Toxic Substances, 703-305-5944)
Use Restrictions
• In May of 1991, EPA proposed amendments to the existing Restricted
Use Classification (RUG) regulations (40 CFR Part 152, Subpart I)
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Federal Statutes and Regulations
to add criteria pertaining to the groundwater contamination potential
of pesticides (56 FR 22076). The criteria would be used to determine
which pesticides should be considered for restricted use
classifications to protect groundwater. A policy statement is expected
to be issued in late 2000. (Contact: Joseph Hogue, United States EPA
Office of Prevention, Pesticides, and Toxic Substances, 703-308-
9072)
Tolerances and Exemptions
• EPA expects to reassess pesticide tolerances and exemptions for raw
and processed foods established prior to August 3,1996 (40 CFR Part
180,40 CFR Part 185,40 CFR Part 186), to determine whether they
meet the standard of the Federal Food, Drug and Cosmetic Act
(FFDCA). FFDCA section 408 (q), as amended by the Food Quality
Protection Act, requires that EPA conduct this reassessment on a
phased 10-year schedule. For the current phased schedule, EPA is
required to complete reassessments as follows: 33% by August 3,
1999, 66% by August 3, 2002, and 100% by August 3, 2006. Based
on its reassessment, EPA will likely propose a series of regulatory
actions to modify or revoke tolerances. (Contacts: Robert McNally,
United States EPA, Office of Prevention, Pesticides and Toxic
Substances, 703-308-8085 and Joseph Nevola, United States EPA
Office of Prevention Pesticides and Toxic Substances, 703-308-8037)
Regulations specifying policies and procedures under which the EPA
can establish food tolerances associated with the use of pesticides
under emergency exemptions (40 CFR Part 176) are expected to be
finalized in late 2000. The EPA issues emergency exemptions for
temporary use of pesticides where emergency conditions exist. Under
FFDCA, as amended by the Food Quality Protection Act, EPA must
establish time-limited tolerances for such pesticides if the use is likely
to result in residues in food. (Contact: Joseph Hogue, United States
EPA Office of Prevention, Pesticides, and Toxic Substances, 703-
308-9072)
EPA proposed a rule to adjust and update the fee structure and fee
amounts for tolerance actions, which are required under FFDCA (40
CFR section 180.33). The rule is expected to finalized in late 2000.
(Contact: Carol Peterson, United States EPA, Office of Prevention,
Pesticides, and Toxic Substances, 703-305-6558)
Revisions to regulations on emergency exemptions under section 18
of FIFRA, are expected to be issued in late 2001 (40 CFR Part 166).
EPA is considering revisions in four areas: 1) Options for increased
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Federal Statutes and Regulations
authority for states to administer certain aspects of the exemption
process, and/or increased use by the EPA of multi-year exemptions;
2) the use of emergency exemptions to address pesticide resistance;
3) the possibility of granting exemptions based upon reduced risk
considerations; and 4) definitions of emergency situation and
significant economic loss, which would affect whether or not an
exemption may be granted. (Contact: Joseph Hogue, United States
EPA Office of Prevention, Pesticides, and Toxic Substances, 703-
308-9072)
Pesticide Storage and Disposal
• In 1994, EPA proposed a rule, authorized under section 19 of FIFRA,
to establish standards for pesticide containers and secondary
containment relating to the distribution and sale of pesticides (59 FR
6712). Standards are expected to be developed for the removal of
pesticides from containers, rinsing containers, container design,
container labeling, container refilling, the containment of stationary
bulk containers and for the containment of pesticide dispensing areas
(40 CFR Part 165, 40 CFR Part 156). A final rule is expected to be
published in late 2000. (Contact: Nancy Fitz, United States EPA,
Office of Prevention, Pesticides and Toxic Substances, 703-305-
7385)
Exports
• The Rotterdam Agreement, signed in 1998, requires that certain
banned or severely restricted hazardous chemicals are subject to
intensive information exchange procedures, and if an importing
country decides against import, exporting countries are obligated to
prohibit export to that country. Twenty-four pesticides are currently
covered by the treaty. As a result of the United States signing of this
treaty, EPA has drafted legislation that allows it in the future to
propose revisions to its pesticide export policy. (Contact: Cathleen
Barnes,'United States EPA Office of Prevention, Pesticides and Toxic
Substances, 703-305-7101)
Worker Protection
• EPA has proposed a change to the Worker Protection Standards
(WPS) of FIFRA (40 CFR Part 170). Specifically, the glove
requirements may be modified to allow glove liners to be worn inside
chemically resistant gloves. The proposed rule will be finalized in
2001. (Contact: Kevin Keaney, United States EPA Office of
Prevention, Pesticides and Toxic Substances, 703-305-5557)
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Compliance and Enforcement History
VII. COMPLIANCE AND ENFORCEMENT HISTORY
Background
Until recently, EPA has focused much of its attention on measuring
compliance with specific environmental statutes. This approach allows the
Agency to track compliance with the Federal Insecticide, Fungicide, and
Rodenticide Act, the Clean Air Act, the Resource Conservation and Recovery
Act, the Clean Water Act, and other environmental statutes. Within the last
several years, the Agency has begun to supplement single-media compliance
indicators with facility-specific, multimedia indicators of compliance. In
doing so, EPA is in a better position to track compliance with all statutes at
the facility level, and within specific industrial sectors.
A major step in building the capacity to compile multimedia data for
industrial sectors was the creation of EPA's Integrated Data for Enforcement
Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's
single-media databases, extract compliance records, and match the records to
individual facilities. The IDEA system can match Air, Water, Waste,
Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
facility, and generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic area and
corporate holder. As the capacity to generate multimedia compliance data
improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of success
for compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation and enforcement data from the IDEA system, this
section provides information regarding the historical compliance and
enforcement activity of this sector. In order to mirror the facility universe
reported in the Toxic Chemical Profile, the data reported within this section
consists of records only from the TRI reporting universe. With this decision,
the selection criteria are consistent across sectors with certain exceptions.
For the sectors that do not normally report to the TRI program, data have
been provided from EPA's Facility Indexing System (FINDS) which tracks
facilities in all media databases. Please note, in this section, EPA does not
attempt to define the actual number of facilities that fall within each sector.
Instead, the section portrays the records of a subset of facilities within the
sector that are well defined within EPA databases.
As a check on the relative size of the full sector universe, most notebooks
contain an estimated number of facilities within the sector according to the
Bureau of Census (See Section II). With sectors dominated by small
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businesses, such as metal finishers and printers, the reporting universe within
the EPA databases may be small in comparison to Census data. However, the
group selected for inclusion in this data analysis section should be consistent
with this sector's general make-up.
Following this introduction is a list defining each data column presented
within this section. These values represent a retrospective summary of
inspections and enforcement actions, and reflect solely EPA, state, and local
compliance assurance activities that have been entered into EPA databases.
To identify any changes in trends, the EPA ran two data queries, one for the
past five calendar years (April 1,1992 to March 31,1997) and the other for
the most recent twelve-month period (April 1,1996 to March 31,1997). The
five-year analysis gives an average level of activity for that period for
comparison to the more recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media databases.
These databases do not provide data on whether inspections are state/local or
EPA-led. However, the table breaking down the universe of violations does
give the reader a crude measurement of the EPA's and states' efforts within
each media program. The presented data illustrate the variations across EPA
regions for certain sectors.5 This variation may be attributable to state/local
data entry variations, specific geographic concentrations, proximity to
population centers, sensitive ecosystems, highly toxic chemicals used in
production, or historical noncompliance. Hence, the exhibited data do not
rank regional performance or necessarily reflect which regions may have the
most compliance problems.
Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) ~ assigns a common facility number to
EPA single-media permit records. The FINDS identification number allows
EPA to compile and review all permit, compliance, enforcement, and
pollutant release data for any given regulated facility.
Integrated Data for Enforcement Analysis (IDEA) -- is a data integration
system that can retrieve information from the major EPA program office
5 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD,
PA, VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK,
TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X
(AK, ID, OR, WA)."
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databases. IDEA uses the FINDS identification number to link separate data
records from EPA's databases. This allows retrieval of records from across
media or statutes for any given facility, thus creating a "master list" of
records for that facility. Some of the data systems accessible through IDEA
are: AFS (Air Facility Indexing and Retrieval System, Office of Air and
Radiation), PCS (Permit Compliance System, Office of Water), RCRIS
(Resource Conservation and Recovery Information System, Office of Solid
Waste), NCDB (National Compliance Data Base, Office of Prevention,
Pesticides, and Toxic Substances), CERCLIS (Comprehensive Environmental
and Liability Information System, Superfund), and TRIS (Toxic Release
Inventory System). IDEA also contains information from outside sources
such as Dun and Bradstreet and the Occupational Safety and Health
Administration (OSHA). Most data queries displayed in notebook sections
IV and VII were conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search -- are based on the universe of TRI reporters within the
listed SIC code range. For industries not covered under TRI reporting
requirements (metal mining, nonmetallic mineral mining, electric power
generation, ground transportation, water transportation, and dry cleaning), or
industries in which only a very small fraction of facilities report to TRI (e.g.,
printing), the notebook uses the FINDS universe for executing data queries.
The SIC code range selected for each search is defined by each notebook's
selected SIC code coverage described in section II.
Facilities Inspected — indicates the level of EPA and state agency
inspections for the facilities in this data search. These values show what
percentage of the facility universe is inspected in a one-year or five-year
period.
Number of Inspections ~ measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
Average Time Between Inspections ~ provides an average length of time,
expressed in months, between compliance inspections at a facility within the
defined universe.
Facilities with One or More Enforcement Actions -- expresses the number
of facilities that were the subj ect of at least one enforcement action within the
defined time period. This category is broken down further into federal and
state actions. Data are obtained for administrative, civil/judicial, and criminal
enforcement actions. Administrative actions include Notices of Violation
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(NOVs). A facility with multiple enforcement actions is only counted once
in this column, e.g., a facility with 3 enforcement actions counts as 1 facility.
Total Enforcement Actions — describes the total number of enforcement
actions identified for an industrial sector across all environmental statutes.
A facility with multiple enforcement actions is counted multiple times, e.g.,
a facility with 3 enforcement actions counts as 3.
State Lead Actions — shows what percentage of the total enforcement
actions are taken by state and local environmental agencies. Varying levels
of usage by states of EPA data systems may limit the volume of actions
recorded as state enforcement activity. Some states extensively report
enforcement activities into EPA data systems, while other states may use
their own data systems..
Federal Lead Actions ~ shows what percentage of the total enforcement
actions are taken by the United States Environmental Protection Agency.
This value includes referrals from state agencies. Many of these actions
result from coordinated or joint state/federal efforts.
Enforcement to Inspection Rate -- is a ratio of enforcement actions to
inspections, and is presented for comparative purposes only. This ratio is a
rough indicator of the relationship between inspections and enforcement. It
relates the number of enforcement actions and the number of inspections that
occurred within the one-year or five-year period. This ratio includes the
inspections and enforcement actions reported under the Clean Water Act
(CWA), the Clean Air Act (CAA) and the Resource Conservation and
Recovery Act (RCRA). Inspections and actions from the TSCA/FIFRA/
EPCRA database are not factored into this ratio because most of the actions
taken under these programs are not the result of facility inspections. Also,
this ratio does not account for enforcement actions arising from non-
inspection compliance monitoring activities (e.g., self-reported water
discharges) that can result in enforcement action within the CAA, CWA, and
RCRA.
Facilities with One or More Violations Identified — indicates the
percentage of inspected facilities having a violation identified in one of the
following data categories: In Violation or Significant Violation Status
(CAA); Reportable Noncompliance, Current Year > Noncompliance,
Significant Noncompliance (CWA); Noncompliance and Significant
Noncompliance (FIFRA, TSCA, and EPCRA); Unresolved Violation and
Unresolved High Priority Violation (RCRA). The values presented for this
column reflect the extent of noncompliance within the measured time frame,
but do not distinguish between the severity of the noncompliance. Violation
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Compliance and Enforcement History
status may be a precursor to an enforcement action, but does not necessarily
indicate that an enforcement action will occur.
Media Breakdown of Enforcement Actions and Inspections -- four
columns identify the proportion of total inspections and enforcement actions
within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
column is a percentage of either the "Total Inspections," or the "Total
Actions" column.
VILA. Fertilizer, Pesticide, and Agricultural Chemical Industry Compliance History
Table 25 provides an overview of the reported compliance and enforcement
data for the Fertilizer, Pesticide, and Agricultural Chemical Industry over
five years from April 1992 to April 1997. These data are also broken out by
EPA Regions thereby permitting geographical comparisons. A few points
evident from the data are listed below.
• About 75 percent of agricultural chemical facility inspections and
73 percent of enforcement actions occurred in EPA Regions IV,
V, VI, and VII.
; • Region IX had the highest ratio of enforcement actions to
inspections (0.13) and the longest average time between
inspections .(21 months). This indicates that fewer inspections
were conducted in relation to the number of facilities in the
Region, but that these inspections were more likely to result in an
enforcement action than inspections conducted in other Regions.
• With the exception of Region I, in which no inspections or
enforcement actions were carried out in between 1992 and 1997,
Region VIII had the lowest enforcement to inspection rate (0.03).
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Table 25: Five-Year Enforcement and Compliance Summary for the Fertilizer, Pesticide, and
Agricultural Chemical Industry
A
Region
I
II
III
IV
V
VI
VII
vni
IX
X
TOTAL
B
Facilities
in
Search
3
11
18
77
35
34
43
9
25
8
263
c
Facilities
Inspected
0
8
16
44
23
21
31
5
10
6
164
D
Number of
Inspections
0
50
123
449
128
167
225
33
72
46
1,293
E
Average
Months
Between
Inspections
--•
13
9
10
16
12
11
16
21
10
12
F
Facilities with
1 or More
Enforcement
Actions
0
3
2
15
4
5
8
1
5
4
47
G
Total
Enforcement
Actions
0
4
10
41
7
9
17
1
9
4
102
H
Percent
State
Lead
Actions
0%
75%
80%
83%
57%
56%
71%
100%
78%
25%
74%
I
Percent
Federal
Lead
Actions
0%
25%
20%
17%
43%
44%
29%
0%
22%
75%
26%
J
Enforcement
to Inspection
Rate
--
0.08
0.08
0.09
0.05
0.05
0.08
0.03
0.13
0.09
0.08
Source: Data obtained from EPA's Integrated Data for Enforcement Analysis (IDEA) system in 1997.
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VII.B. Comparison of Enforcement Activity Between Selected Industries
Tables 26 and 27 allow the compliance history of the agricultural chemical
sector to be compared to the other industries covered by the industry sector
notebooks. Comparisons between Tables 26 and 27 permit the identification
of trends in compliance and enforcement records of the various industries by
comparing data covering five years (April 1992 to April 1997) to that of the
last year for which data were available (April 1996 to April 1997). Some
points evident from the data are listed below.
° The agricultural chemical sector was inspected more frequently
than most of the sectors shown (12 months on average between
inspections).
• Between 1992 and 1997, the industry had a higher enforcement
to inspection rate than most sectors (0.08); however, in 1997 the
ratio decreased to 0.05 which is lower than most sectors.
« The agricultural chemical sector had one of the highest
percentages of facilities inspected with one or more violations (97
percent) in 1997, but one of the lowest percentages of facilities
with one or more enforcement actions (5 percent).
Tables 28 and 29 provide a more in-depth comparison between the Fertilizer,,
Pesticide, and Agricultural Chemical Industry and other sectors by breaking
out the compliance and enforcement data by environmental statute. As in the
previous Tables (Tables 26 and 27), the data cover the years 1992 to 1997
(Table 28) and 1997 (Table 29) to facilitate the identification of recent trends.
A few points evident from the data are listed below.
• The percent of inspections carried out under each environmental
statute has changed only slightly between the average of the years
1992 to 1997 and that of the past year. The Clean Air Act
accounted for the most inspections (43 percent) during this
period. This increased to almost half of all agricultural chemical
facility inspections (49 percent) in 1997.
• The percent of enforcement actions taken under each
environmental statute changed significantly from the 1992 to
1997 period to the past year. Enforcement actions taken under the
Clean Air Act increased from 39 percent to 55 percent and
enforcement actions taken under RCRA increased from 30
percent to 3 6 percent. At the same time, the enforcement actions
taken under the Clean Water Act went from 20 percent in 1992 to
1995 to no actions in 1997.
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Compliance and Enforcement History
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Sector Notebook Project
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Compliance and Enforcement History
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Compliance and Enforcement History
VII.C. Review of Major Legal Actions
Major Cases/Supplemental Environmental Projects
This section provides summary information about major cases that have
affected this sector, and a list of Supplemental Environmental Projects
(SEPs).
VII.C.l. Review of Major Cases
As indicated in EPA's Enforcement Accomplishments Report, FY1995 and
FY1996publications, about 17 significant enforcement actions were resolved
between 1995 and 1996 for the Fertilizer, Pesticide, and Agricultural
Chemical Industry.
American Cyanamid Company On June 28, 1995, Region II issued an
administrative complaint against American Cyanamid Company for
violations at its Lederle Laboratories facility located in Pearl River, New
York. The complaint proposed assessment of a $272,424 fine for the
company's failure to submit timely TRI Form Rs for 1,1,1-trichloroethane,
naphthalene, phosphoric acid, toluene, manganese compounds and zinc
compounds for the reporting years 1990, 1991, 1992, and 1993.
Precision Generators, Inc. The Regional Administrator signed a consent
order in the Precision Generators, Inc., a FIFRA case, in which the
respondent agreed to pay the proposed penalty of $4,000. The administrative
complaint cited the respondent's sale and misbranding of its unregistered
pesticide product ethylene fluid used to accelerate the ripening of fruits and
vegetables. Such a product is a "plant regulator" falling within the definition
of "pesticide" in FIFRA.
E.C. Geiger, Inc. On August 18, 1995, the Regional Administrator signed
a consent agreement and consent order finalizing settlement of the
administrative proceeding against E.C. Geiger, Inc. of Harleysville,
Pennsylvania, for violations of sections 12(a)(l)(A) and (B) of FIFRA, 7
U.S.C. section 136j(a)(l)(A) and (B). The complaint alleged that during
1992, Geiger sold or distributed an unregistered and misbranded pesticide
product, a rooting hormone called "Indole-3-butyric Acid-Horticultural
Grade." For these violations the complaint sought a $ 14,000 penalty. Geiger
has agreed to pay a penalty of $8,900.
Rhpne-Poulenc, Inc. Region III reached a settlement with Rhone-Poulenc,
Inc., in a Part II administrative action brought for violations of RCRA boiler
and industrial furnace (BIF) regulations at Rhone-PoulenC's Institute, West
Virginia plant. The settlement calls for Rhone-Poulenc to pay a penalty of
over $244,000 and to undertake numerous compliance tasks.
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Compliance and Enforcement History
IMC-Agrico Company On November 8,1994, the Regional Administrator
ratified a consent decree between the United States and IMC-Agrico
Company concerning IMC's violations of section 301 (a) of the CWA. IMC
owns and operates phosphate rock mines and associated processing facilities
in Florida and Louisiana. Eight of its mineral extraction operations located
throughout Florida and its Port Sutton Phosphate Terminal located in Tampa,
Florida, were the subject of this referral. The action arose out of IMC's
violation of its permit effluent limits for a variety of parameters including
dissolved oxygen, suspended solids, ammonia, and phosphorous, as well as
non-reporting and stormwater violations at the various facilities-over 1,500
permit violations total. The case was initiated following review of the facility
discharge monitoring reports and EPA and state inspections of the sites. The
consent decree settlement involved an up-front payment of $835,000 and a
$265,000 Supplemental Environmental Project (SEP). The pollution
prevention SEP involved converting IMC's scrubber discharge and intake
water systems into a closed loop system, greatly reducing pollution loading
at the Port Sutton facility, by April 1995.
J.T. Eaton & Company, Inc. J.T. Eaton & Company, Inc. distributed and
sold at least 13 unregistered pesticides (mostly rodenticides). These
unregistered pesticides resulted from varying the form of the rodent bait and
the packaging of several of Eaton's registered products (e.g., registered as a
bulk product) but sold in ready-to-use place packs. The company also
distributed and sold a misbranded pesticide product and made inaccurate
claims in advertising for another product. A stop sale, use, or removal order
and an administrative complaint were issued simultaneously on March 23,
1995. The penalty assessed in the complaint was $67,500. The complaint
was settled on August 25, 1995, for $40,000.
Citizens Elevator Co., Inc. Citizens Elevator Co. repackaged and
distributed and sold the pesticide "Preview" in five gallon buckets, many
bearing pie filling labels, to at least 24 customers, constituting the distribution
and sale of an unregistered pesticide. The complaint, issued June 30, 1994,
assessed a penalty of $108,000. In supplemental environmental projects for
the prevention of spills of pesticides and fertilizers and the safer, more
efficient storage and application of pesticides and fertilizer. The respondent
spent $184,771. A consent agreement signed June 30,1995, settled the case
for $8,400.
Nitrogen Products, Inc. On September 25, 1995, a joint stipulation and
order of dismissal was filed in the United States District Court for the Eastern
District of Arkansas. Nitrogen Products, Inc. (NPI), agreed to pay a civil
penalty of $243,600 to the United States for violations of the Clean Air Act,
and Subparts A and R of 40 CFR Part 61. The foreign parent corporation,
Internationale Nederlanden Bank, N.V., acquired the facility through
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Compliance and Enforcement History
foreclosure and expended over $2 million to cover the phosphogypsum stack
andregrade.
Micro Chemical, Inc. The illegal transportation of hazardous waste by a
Louisiana pesticide formulation company, Micro Chemical, Inc., to an
unpermitted disposal facility in violation of RCRA resulted in a $500,000
fine, five years of probation, and compliance with corrective action measures
contained in a corrective action administrative order on consent. In March
1990, Micro Chemical transported 100 cubic yards of hazardous waste from
its facility to a field in Baskin, Louisiana-a location that did not have a RCRA
permit. After its discovery, it was removed under the Louisiana Department
of Agriculture's guidance. Micro Chemical has taken measures to stabilize
and prevent the spread of pesticide contamination from the Micro Chemical
facility site, as required by a RCRA 3008(h)"corrective action administrative
order on consent. The order will result in the removal of all contaminated
soil at the site, and the remediation of all off-site contamination that has
migrated into a drainage basin located adjacent to the site.
Chempace Corporation On September 26, 1996, Region V PTES filed a
civil administrative complaint against Chempace corporation of Toledo, Ohio
alleging 99 counts for the distribution or sale of unregistered andmisbranded
pesticides, and pesticide production in unregistered establishments. The total
proposed penalty in the complaint is $200,000. The case is significant in that
Chempace had, previous to the complaint, canceled all of the company's
pesticide product registrations pursuant to section 4 of FIFRA, as well as their
establishment registration pursuant to section 7. However, the company
continued to produce and sell those canceled pesticides in a facility that was
not registered.
Northrup King Co. On September 30, 1996, as a result of a FIFRA
inspection conducted by Region V on March 27-28,1996, Region V issued
a FIFRA civil complaint to Northrup King Co. of Golden Valley, Minnesota.
The pesticide involved in the case is a genetically engineered corn seed that
protects against the corn borer. Because this case is the first FIFRA
complaint involving a genetically engineered pesticide, the case is nationally
significant. The complaint alleged 21 counts of sale and distribution of an
unregistered pesticide, 21 counts for failure to file a Notice of Arrival for
pesticide imports, and 8 counts of pesticide production in unregistered
establishments, for a total proposed penalty of $206,500. A consent
agreement and consent order was filed simultaneously with, and in resolution
of the complaint. The respondent agreed to pay $165,200, which is the
largest penalty collected by Region V under FIFRA.
Micro Chemical. Micro Chemical is a pesticide formulating, mixing, and
packaging facility 3,000 feet up gradient of the Winnsboro's groundwater
well complex. In March 1990, a release from the facility was reported by a
citizen. Investigations revealed that the company had attempted to dump 100
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Compliance and Enforcement History
cubic yards of pesticide contaminated soil offsite. People living near the
dump site became ill from the fumes and the state ordered the soil to be
returned to Micro Chemical. Ultimately a criminal case was initiated for the
midnight dumping. Other storage violations detected were the subject of an
administrative complaint issued in September 1992'. A RCRA 3008(h) order
on consent was entered into on September 1994 to remediate the site. In
resolving the September 1992 complaint, a final order was issued on March
28,1996. Micro Chemical agreed to pay a penalty of $25,000 and agreed to
fund a SEP valued at $25,000. The SEP established collection events for
household waste and waste pesticides in the Franklin Parish area. During
FY96, the SEP enabled about 100 tons of waste to be collected and properly
disposed.
Terra Industries, Inc. At the request of the Chemical Emergency
Prevention and Preparedness Office (CEPPO), and in accordance with section
112(r) of the CAA, EPA released the results of its investigation into the cause
of an explosion of the ammonium nitrate plant at this nitrogen fertilizer
manufacturing facility. The report released in January 1996 identifies
numerous unsafe operating procedures at the plant as contributing factors to
the explosion, and recommends certain standard operating procedures which
would help prevent similar occurrences at ammonium nitrate production
facilities.
The Terra explosion occurred on December 13,1994, killing four individuals
and injuring 18 others. It also resulted in the release of approximately 5,700
tons of anhydrous ammonia to the air and approximately 25,000 gallons of
nitric acid to the ground and required evacuation over a two-state area of over
2,500 persons from their homes.
In a subsequent action, an administrative civil complaint alleging violations
of EPCRA sections 213 and 313, and section 8(a) of TSCA, was filed citing
that Terra International failed to submit Toxic Release Inventory (TRI)
information to EPA in a timely manner, and data submitted to EPA by Terra
failed to include releases of more than 17 million pounds of toxic chemicals
to the environment on-site.
Pfizer/AgrEvo Reporting of unreasonable adverse effects information is
required under FIFRA section 6(a)(2), and failure to submit such reports has
resulted in a $192,000 settlement involving AgrEvo Environmental Health,
Inc. and Pfizer, Inc. The case arose in early 1994 after an individual reported
disabling neurological symptoms and chemical sensitivity after using RID
products to kill lice. The ensuing EPA investigation revealed numerous
additional unreported incidents involving RID which is manufactured by
AgrEvo and distributed by Pfizer. EPA amended the complaint charging 24
counts against each company. FIFRA 6(a)(2) requires pesticide registrants
to submit to EPA any additional information (beyond that submitted in the
pesticide registration process) that they have regarding unreasonable adverse
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Compliance and Enforcement History
effects of their pesticides on human health or the environment. The
information is used by the Agency in-the determination of risks associated
with pesticides.
Rohm and Haas Company This complaint cited Rohm and Haas for 66
violations under FIFRA section 12(a)(l)(c), for the distribution or sale of a
registered pesticide the composition of which differed from the composition
as described in its registration under FIFRA section 3. EPA registers
pesticides based upon the accurate assessment of components used in the
manufacture of the product. Use of an unapproved formula can lead to
production of a pesticide for which no assessment of risk has been
determined or result in unknown synergistic effects. Following settlement
negotiations, and in accordance with the FIFRA Enforcement Response
Policy, the original penalty of $330,000 was reduced to $118,800, based on
a 20% reduction to the gravity level, a 40% reduction for immediate self-
disclosure, mitigation, and corrective actions, and a 15% reduction for good
attitude, cooperation, and efforts to comply with FIFRA.
VII.C.2. Supplementary Environmental Projects (SEPs)
SEPs are compliance agreements that reduce a facility's non-compliance
penalty in return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities that can
reduce the future pollutant loadings of a facility. Information on SEP cases
can be accessed via the Internet at http ://es.epa.gov/oeca/sep.
Sector Notebook Project
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Agricultural Chemicallndustry
Activities and Initiatives
VIII. COMPLIANCE ASSURANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector and
public agencies to voluntarily improve the sector's environmental
performance. These activities include those initiated independently by
industrial trade associations. In this section, the notebook also contains a
listing and description of national and regional trade associations.
VIII.A. Sector-Related Environmental Programs and Activities
National Agricultural Compliance Assistance Center (Ag Center)
EPA's Office of Compliance, with the support from the United States
Department of Agriculture (USD A), developed EPA's National Agriculture
Compliance Assistance Center (Ag Center). The Ag Center offers
comprehensive, easy-to-understand information about approaches to
compliance that are both environmentally protective and agriculturally sound.
The Ag Center focuses on providing information about EPA's own
requirements. In doing so, the center relies heavily on existing sources of
agricultural information and established distribution channels. Educational
and technical information on agricultural production is provided by the
USDA and other agencies, but assistance in complying with environmental
requirements has not traditionally been as readily available. The Ag Center
is currently working with USDA and other federal and state agencies to
provide the agricultural community, including regional and state regulatory
agencies, with a definitive source for federal environmental compliance
information. The Ag Center offers information on a variety of topics,
including the following:
• Pesticides
• Animal waste management
• Emergency planning and response
• Groundwater and surface water
• Tanks / containment
• Solid / hazardous waste
Through a toll-free telephone number and a website that is regularly updated
and expanded, the Ag Center offers a variety of resources including:
• current news, compliance policies and guidelines, pollution
prevention information, sources of additional information and
expertise, and summaries of regulatory initiatives and
requirements
• user-friendly materials that consolidate information about
compliance requirements, pollution prevention, and technical
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assistance resources for use by regional and state assistance and
educational programs, trade associations, businesses, citizens, and
local governments
• agriculture-related information on reducing pollution and using
the latest pollution prevention methods and technologies
• information on ways to reduce the costs of meeting environmental
requirements, including identification of barriers to compliance
The Ag Center's toll-free number is 1-888-663-2155 and the website address
is: http://es.epa.gov/oeca/ag/
National Pesticide Information Retrieval System (NPIRS)
Purdue University has developed a collection of databases through their
Center for Environmental and Regulatory Information Systems, one of which
is the National Pesticide Information Retrieval System. NPIRS is a collection
of six databases related to pesticides, including product registration document
information, data submitter information, residue tolerances, fact sheets,
material safety data sheets, and the daily federal register. Full search access
to the NPIRS databases is by annual subscription.
Association of American Plant Food Control Officials (AAPFCO) Label Recommendations
The AAPFCO is considering a set of recommendations issued by a task force
of fertilizer producers and state officials. These recommendations call for
labeling and standards for non-nutrient constituents in fertilizer and directions
that will allow users to apply fertilizers at a rate that will not exceed these
standards. One proposed addition to labels is to list all raw materials,
including recycled wastes; however, the concentration of these materials will
not be required (ARA, 1997).
Agricultural Research Institute
ARI was founded in 1951 as a part of the National Academy of Sciences,
then incorporated separately in 1973. ARI analyzes agricultural problems and
promotes research by its members to solve them. ARI publishes annual
meeting minutes, a directory, books, pamphlets, and newsletters.
National Association of State Departments of Agriculture (NASDA)
NASD A was founded in 1916 by directors of state and territorial departments
of agriculture to coordinate policies, procedures, laws, and activities between
the .states and federal agencies and Congress. NASDA conducts research,
holds a trade show, and distributes several bulletins, newsletters, and
directories.
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ChemAlliance
EPA's Office of Compliance developed ChemAlliance, a new Compliance
Assistance Center for the chemical industry. Among its features is an exciting
"expert help," which offers an interactive guide to finding compliance
resources specific to a user's needs. Take a "virtual plant tour" to find out
which regulations apply to your company's operations by clicking on a
detailed chemical plant illustration. ChemAlliance can be reached at
1-800-672-6048; its web site is located at. http://www.chemalliance.org,
VHI.B. EPA Voluntary Programs
Pesticide Environmental Stewardship Program (PESP)
The Pesticide Environmental Stewardship Program (PESP) is a broad effort
by EPA, USD A, and the FDA to reduce pesticide use and risk in both
agriculture and nonagricultural settings. In September 1993, the three
agencies announced a federal commitment to two major goals: 1) developing
specific use/risk reduction strategies that include reliance on biological
pesticides and other approaches to pest control that are thought to be safer
than traditional chemical methods, and 2) by the year 2000, having 75 percent
of United States agricultural acreage adopt integrated pest management
programs.
A key part of the PESP is the public/private partnership which began when
EPA, USD A, and FDA announced the partnership and more than 20 private
organizations signed on as charter members. All organizations with a
commitment to pesticide use/risk reduction are eligible to join the PESP,
either as Partners or Supporters. The PESP program has -35 partners.
Together, these partners represent at least 45,000 pesticide users. The
program has a goal of adding 35 new partners per year.
33/50 Program
The 33/50 Program is a ground breaking program that has focused on reducing
pollution from seventeen high-priority chemicals through voluntary partnerships with
industry. The program's name stems from its goals: a 33% reduction in toxic
releases by 1992, and a 50% reduction by 1995, against a baseline of 1.5 billion
pounds of releases and transfers in 1988. The results have been impressive: 1,300
companies have joined the 33/50 Program (representing over 6,000 facilities) and
have reached the national targets a year ahead of schedule. The 33% goal was
reached in 1991, and the 50% goal ~ a reduction of 745 million pounds of toxic
wastes — was reached in 1994. The 33/50 Program can provide case studies on many
of the corporate accomplishments in reducing waste (Contact 33/50 Program Director
David Sarokin--202-260-6396).
Table 30 lists those companies participating in the 33/50 program that reported the
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SIC codes 2873,2874,2875, and 2879 to TRI. Some of the companies shown also
listed facilities that are not producing agricultural chemicals. The number of
facilities within each company that are participating in the 33/50 program and that
report SIC codes 2873, 2874, 2875, and 2879 is shown. Where available and
quantifiable against 1988 releases and transfers, each company's 33/50 goals for
1995 and the actual total releases and transfers and percent reduction between 1988
and 1995 are presented. Eleven of the seventeen target chemicals were reported to
TRI by agricultural chemical facilities in 1995.
Table 30 shows that 24 companies comprised of 78 facilities reporting SIC 287
participated in the 33/50 program. For those companies shown with more than one
agricultural chemical facility, all facilities may not have participated in 33/50. The
33/50 goals shown for companies with multiple facilities, however, were company-
wide, potentially aggregating more than one facility and facilities not carrying out
agricultural chemical operations. In addition to company-wide goals, individual
facilities within a company may have had their own 33/50 goals or may have been
specifically listed as not participating in the 33/50 program. Since the actual percent
reductions shown in the last column apply to only the companies' agricultural
chemical facilities, direct comparisons to those company goals incorporating non-
agricultural chemical facilities or excluding certain facilities may not be possible.
For information on specific facilities participating in 33/50, contact David Sarokin
(202-260-6907) at the 33/50 Program Office.
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Table 30: Fertilizer, Pesticide, and Agricultural Chemical Industry Participation in the 33/50
Program
Parent Company
(Headquarters Location)
AMERICAN HOME PRODUCTS CORP.
MADISON, NJ
ARCADIAN CORP.
MEMPHIS, TN
BAY ZINC CO. INC.
MOXEE CITY, WA
CHEM-TECH LTD.
DBS MOINES, IA
CHEVRON CORP.
SAN FRANCISCO, CA
CONAGRA INC.
OMAHA, NE
E.I. DU PONT DE NEMOURS & CO
WILMINGTON, DE
ELF AQUITAINE INC.
NEW YORK, NY
FIRST MISSISSIPPI CORP.
JACKSON, MS
FMC CORPORATION
CHICAGO, IL
GLAXO WELLCOME INC.
RESEARCH TRIANGLE PARK, NC
GOWAN COMPANY
YUMA,AZ
IMC FERTILIZER GROUP INC.
NORTHBROOK, IL
ISK AMERICAS INC.
ATLANTA, GA
LAROCHE HOLDINGS INC.
ATLANTA, GA
MALLINCKRODT GROUP INC.
SAINT LOUIS, MO
MILES INC.
PITTSBURGH, PA
MONSANTO COMPANY
SAINT LOUIS, MO
RHONE-POULENC INC.
MONMOUTH JUNCTION, NJ
SC JOHNSON & SON INC.
RACINE, WI
SANDOZ CORPORATION
NEW YORK, NY
TALLEY INDUSTRIES
PHOENIX, AZ
UNIVERSAL COOPERATIVES INC.
MINNEAPOLIS, MN
UNOCAL CORPORATION
LOS ANGELES, CA
Total
Company-Owned
Facilities Reporting
33/50 Chemicals
2
6
1
1
3
6
2
1
7
5
1
1
7
2
1
1
1
1
.21
1
3
1
1
2
78
Company- Wide
% Reduction
Goal1
(1988 to 1995)
49
0
50
90
50
8
50
49
0
50
37
0
0
50
0
44
38
23
50
50
50
0
70
50
...
1988 TRI Releases
and Transfers of
33/50 Chemicals
(pounds)2
47,950
4,340
77,250
800
8,746
17,086
144,412
3,068
70.1,144
6,190
1,125
0
56,350
884,412
17,590
0
39,822
0
3,128,263
19,086
207,086
8,243
17,750
0
5,390,713
1995 TRI Releases
and Transfers of
33/50 Chemicals
(pounds)2
73,876
10,127
252
0
0
5,238
440,370
0
214,334
2,339
0
2,207
51,548
726,713
0
0
6,650
1,260
1,392,117
20,096
87,000
2,289
1,265
9
3,037,690
% of Change
per Facility
(1988-1995)
-54
-133
100
100
100
69
-205
100
69
62
100
—
9
18
100
.
83
55
-5
58
72
93
—
44
Source: United States EPA 33/50 Program Office, 1997.
' Company-Wide Reduction Goals aggregate all company-owned facilities which may include facilities not producing agricultural chemicals.
2 Releases and Transfers are ftom facilities only. 1995 33/50 TRI data were not available at time of publication.
* = Reduction goal not quantifiable against 1988 TRI data. ** = Use reduction goal only. *** = No numeric reduction goal.
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Project XL
Project XL was initiated in March 1995 as a part of President Clinton's Reinventing
Environmental Regulation initiative. The projects seek to achieve cost effective
environmental benefits by providing participants regulatory flexibility on the
condition that they produce greater environmental benefits. EPA and program
participants will negotiate and sign a Final Project Agreement, detailing specific
environmental objectives that the regulated entity shall satisfy. EPA will provide
regulatory flexibility as an incentive for the participants' superior environmental
performance. Participants are encouraged to seek stakeholder support from local
governments, businesses, and environmental groups.
There have been at least two Project XL proposals relating to fertilizer
production, however both of these have been either rejected or withdrawn.
PCS Nitrogen (formerly Arcadian Fertilizer) had proposed to reuse stockpiled
phosphogypsum as an ingredient in a soil enhancer. Another proposal by
' Dow Chemical Company in Louisiana was to trade off equipment leak
reductions for relief from some emissions control, monitoring, reporting and
record-keeping requirements.
EPA hopes to implement fifty pilot projects in four categories, including
industrial facilities, communities, and government facilities regulated by
EPA. Applications will be accepted on a rolling basis. For additional
information regarding XL projects, including application procedures and
criteria, see the May 23, 1995 Federal Register Notice. (Contact: Fax-on-
Demand Hotline 202-260-8590, Web: http://www.epa.gov/ProjectXL, or
Christopher Knopes at EPA's Office of Policy, Planning and Evaluation 202-
260-9298)
Climate Wise Program
EPA's ENERGY STAR Buildings Program is a voluntary, profit-based program
designed to improve the energy-efficiency in commercial and industrial buildings.
Expanding the successful Green Lights Program, ENERGY STAR Buildings was
launched in 1995. This program relies on a 5-stage strategy designed to maximize
energy savings thereby lowering energy bills, improving occupant comfort, and
preventing pollution — all at the same time. If implemented in every commercial and
industrial building in the United States, ENERGY STAR Buildings could cut the
nation's energy bill by up to $25 billion and prevent up to 35% of carbon dioxide
emissions. (This is equivalent to taking 60 million cars of the road). ENERGY STAR
Buildings participants include corporations; small and medium sized businesses;
local, federal and state governments; non-profit groups; schools; universities; and
health care facilities. EPA provides technical and non-technical support including
software, workshops, manuals, communication tools, and an information hotline.
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EPA's Office of Air and Radiation manages the operation of the ENERGY STAR
Buildings Program. (Contact: Green Light/Energy Star Hotline at 1 -888-STAR-YES
or Maria Tikoff Vargas, EPA Program Director at 202-23 3 -9178 or visit the ENERGY
STAR Buildings Program website at http://www.epa.gov/appdstar/buildings/)
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of preventing
pollution by encouraging United States institutions to use energy-efficient lighting
technologies. The program saves money for businesses and organizations and creates
a cleaner environment by reducing pollutants released into the atmosphere. The
program has over 2,345 participants which include major corporations, small and
medium sized businesses, federal, state and local governments, non-profit groups,
schools, universities, and health care facilities. Each participant is required to survey
their facilities and upgrade lighting wherever it is profitable. As of March 1997,
participants had lowered their electric bills by $289 million annually. EPA provides
technical assistance to the participants through a decision support software package,
workshops and manuals, and an information hotline. EPA's Office of Air and
Radiation is responsible for operating the Green Lights Program. (Contact: Green
Light/Energy Star Hotline at 1 -888-STARYES or Maria Tikoff Vargar, EPA Program
-- Director, at 202-233-9178)
WasteWi$e Program
The WasteWi$e Program was started in 1994 by EPA's Office of Solid Waste and
Emergency Response. The program is aimed at reducing municipal solid wastes by
promoting waste prevention, recycling collection and the manufacturing and purchase
of recycled products. As of 1997, the program had about 500 companies as
members, one third of whom are Fortune 1000 corporations. Members agree to
identify and implement actions to reduce their solid wastes setting waste reduction
goals and providing EPA with yearly progress reports. To member companies, EPA,
in turn, provides technical assistance, publications, networking opportunities, and
national and regional recognition. (Contact: WasteWi$e Hotline at 1-800-372-9473
or Joanne Oxley, EPA Program Manager, 703-308-0199)
NICE3
The United States Department of Energy is administering a grant program called The
National Industrial Competitiveness through Energy, Environment, and Economics
(NICE3). By providing grants of up to 45 percent of the total project cost, the
program encourages industry to reduce industrial waste at its source and become
more energy-efficient and cost-competitive through waste minimization efforts.
Grants are used by industry to design, test, and demonstrate new processes and/or
equipment with the potential to reduce pollution and increase energy efficiency. The
program is open to all industries; however, priority is given to proposals from
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participants in the forest products, chemicals, petroleum refining, steel, aluminum,
metal casting and glass manufacturing sectors. (Contact:
http//www.oit.doe.gov/access/ niceS, Chris Sifri, DOE, 303-275-4723 or Eric Hass,
DOE, 303-275-4728)
Design for the Environment (DfE)
DfE is working with several industries to identify cost-effective pollution prevention
strategies that reduce risks to workers and the environment. DfE helps businesses
compare and evaluate the performance, cost, pollution prevention benefits, and
human health and environmental risks associated with existing and alternative
technologies. The goal of these projects is to encourage businesses to consider and
use cleaner products, processes, and technologies. For more information about the
DfE Program, call (202) 260-1678. To obtain copies of DfE materials or for general
information about DfE, contact EPA's Pollution Prevention Information
Clearinghouse at (202) 260-1023 or visit the DfE Website at http://es.inel.gov/dfe.
VIII.C. Trade Association/Industry Sponsored Activity
Vin.C.l. State Advisory Groups
Association of American Pesticide Control Officials (AAPCO)
P.O. Box 1249 Members: 55
Hardwick, VT 05843 Staff: 1
Phone: 802-472-6956
Fax: 802-472-6957
E-mail: aapco@plainfield.bypass.com
Formed in 1947, the Association of American Pesticide Control Officials
(AAPCO) consists of state and federal pesticide regulatory officials. All
federal and provincial Canadian officials, officials of all North American
countries involved with the regulation of pesticides may be members of
AAPCO as well. AAPCO holds meetings twice a year and publishes an
annual handbook that contains uniform policies and model pesticide
legislation that the association has adopted.
AAPCO aims to promote uniform and effective state legislation and pesticide
regulatory programs. Its other objectives are to develop inspection
procedures, to promote labeling and safe use of pesticides, to provide
opportunities for members to exchange information, and to work with
industry to promote the usefulness and effectiveness of pesticide products.
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State FIFRA Issues Research and Evaluation Group (SFIREG)
P.O. Box 1249 Members:
Hardwick, VT 05843 10 state representatives
Phone: 802-472-6956
Fax: 802-472-6957
E-mail: aapco@plainfield.bypass.com
The State FIFRA Issues Research and Evaluation Group evolved in 1978 out
of a cooperative agreement between the EPA's Office of Pesticide Programs
(OPP) and the Association of American Pesticide Control Officials
(AAPCO). SFIREG is an independent but related body of AAPCO that
provides state comments to the Office of Pesticide Programs on issues
relating to the manufacture, use and disposal of pesticides. Its membership
is comprised often state representatives, who represent and are selected by
the states in each of the ten EPA Regions.
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VIII.C.2. Trade Associations
Association of American Plant Food Control Officials (AAPFCO)
University of Kentucky Members: 200
Division of Regulatory Services
103 Regional Services Building
Lexington, KY 40546-0275
Phone: 606-257-2668
606-257-2970
Fax: 606-257-7351
The AAPFCO is an organization of state fertilizer control officials from the
United States and Canada who are involved in the administration of fertilizer
regulations and laws. The AAPFCO's purpose is to achieve uniformity
throughout their membership with regards to promoting effective legislation,
adequate sampling, accurate labeling, and safe use of fertilizers, as well as to
study and discuss relevant issues.
Agricultural Retailers Association (ARA)
11701 BormanDr., Ste. 110 Members: 1,100
St. Louis, MO 63146 Staff: 17
Phone:800-844-4900
Fax:314-567-6808
The Agricultural Retailers Association was founded in 1954 and is made up
of dealers, manufacturers, and suppliers of fluid fertilizers and agrichemicals,
as well as equipment manufacturers, retail affiliations, and state association
affiliates. ARA was formerly known as the National Nitrogen Solutions
Association. Their publications include Agricultural Retailers Association-
Membership Directory and Buyer's Guide (annual), Connections, a
bimonthly newsletter, and the Fluid Fertilizer Manual.
Fertilizer Industry Round Table (FIRT)
5234 Glen Arm Rd. Nonmembership
Glen Arm, MD 21057
Phone: 410-592-6271
Fax:410-592-5796
The Fertilizer Industry Round Table was founded in 1951. Participants
include production, technical, and research personnel in the fertilizer
industry. FIRT acts as a forum for discussion of technical and production
problems. They hold an annual meeting and publish the proceedings.
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The Fertilizer Institute (TFI)
5012nd St., NE
Washington, DC 20002
Phone:202-675-8250
Fax: 202-544-8123
Members: 300
Staff: 22
The Fertilizer Institute was founded in 1970 and now has 48 affiliated groups.
Members include producers, manufacturers, retailers, trading firms, and
equipment manufacturers. TFI represents members in various legislative,
educational, and technical areas, and provides information and public
relations programs. Publications include: Directory of Fertilizer References,
annual; Fertilizer Facts and Figures, annual; Fertilizer Institute-Action
Letter, monthly; Fertilizer Record, periodic.
Chemical Manufacturers Association (CMA)
1300 Wilson Blvd. Members: 185
Arlington, VA 22209 Staff: 280
Phone: 703-741-5000
Fax: 703-741-6000
The Chemical Manufacturers Association was founded in 1872 and now has
a budget of $36 million. CMA conducts advocacy and administers research
areas of broad import to chemical manufacturing, such as pollution
prevention and other special research programs. CMA also conducts
committee studies, operates the Chemical Emergency Center (CHEMTREC)
for guidance to emergency service on handling emergencies involving
chemicals and the Chemical Reference Center which offers health and safety
information about chemicals to the public. Publications include semi-
monthly newsletters, ChemEcology and CMA News, and the CMA Directory
and User's Guide.
Chemical Specialties Manufacturers Association (CSMA)
1913 Eye St., NW Members: 425
Washington, DC 20006 Staff: 31
Phone:202-872-8110
Fax:202-872-8114
The Chemical Specialties Manufacturers Association was founded in 1914
and is made up of manufacturers, marketers, formulators, and suppliers of
household, industrial, and personal care chemical specialty products such as
pesticides, cleaning products, disinfectants, sanitizers, and polishes. CSMA
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serves as a liaison to federal and state agencies and public representatives,
provides information and sponsors seminars on governmental activities and
scientific developments.
American Crop Protection Association (ACPA)
1156 15th St., NW, Ste. 400 Members: 82
Washington, DC 20005 Staff: 29
Phone: 202-296-1585
Fax: 202-463-0474
The American Crop Protection Association was founded in 1933 andnowhas
a budget of $7 million. Members include companies involved in producing
or formulating agricultural chemical products including agricultural
fumigants, agricultural scalicides, chemical plant sprays and dusts, defoliants,
soil disinfectants, weed killers, and others. It is comprised of legislative,
regulatory and science departments and publishes a periodic bulletin,
manuals, Growing Possibilities, quarterly, and This Week and Next, weekly.
Western Crop Protection Association (WCPA)
3835 N. Freeway Blvd. Ste. 140 Members: 170
Sacramento, CA 95834 Staff: 6
Phone: 916-568-3660
Fax:916-565-0113
The WCPA is a regional organization of manufacturers, formulators,
distributors, and dealers of basic pesticide chemicals and suppliers of
solvents, diluents, emulsifiers, and containers. They are affiliated with the
American Crop Protection Association. They publish several bulletins and
periodicals.
National Pest Control Association (NPCA)
8100 Oak St. Members: 2,300
Dunn Loring, VA 22027 Staff: 21
Phone:703-573-8330
Fax:703-573-4116
The National Pest Control Association was founded in 1933 and now has a
budget of $2.8 million. Members include companies engaged in control of
insects, rodents, birds, and other pests. NPCA provides advisory services on
'control procedures, new products, and safety and business administration
practices. NPCA sponsors research at several universities, furnishes,
technical information and advice to standards and code writing groups, and
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maintains an extensive library on pests. NPCA publishes many titles
including manuals, newsletters, membership guides, technical releases, and
reports.
International Fertilizer Development Center (IFDC)
PO Box 2040 Nonmembership
Muscle Shoals, AL 35662 Staff: 180
Phone: 205-381-6600
Fax: 205-381-7408
The International Fertilizer Development Center was founded in 1974 and
includes participants such as scientists, engineers, economists and specialists
in market research and development and communications. IFDC uses a $ 13.5
million budget to try to alleviate world hunger by increasing agricultural
production in the tropics and subtropics through development of improved
fertilizers. IFDC sponsors and conducts studies in fertilizer efficiencies and
offers courses on fertilizer production, environmental issues, and crop
sustainability. They maintain greenhouses and laboratories, and publish
several periodicals and manuals.
United Products Formulators and Distributors Association(UPFDA)
1 Executive Concourse No. 103 Members: 102
Duluth,GA 30136 Staff:!
Phone: 404-623-8721
Fax: 404-623-1714
The United Products Formulators and Distributors Association was founded
in 1968 and is made up of companies engaged in formulating and distributing
pesticide products. The UPFDA works to solve problems of member
companies and promote sound and beneficial legislation and to cooperate
with allied industries.
North American Horticultural Supply Association (NAHSA)
1790 Arch St. Members: 135
Philadelphia, PA 19103 Staff: 3
Phone: 215-564-3484
Fax: 215-564-2175
The North American Horticultural Supply Association was founded in 1988
and represents horticultural supplies such as greenhouse building materials
and supplies, pesticides, and fertilizers. The NAHSA works to strengthen
and enhance the relationship between manufacturers and distributors and
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promotes distribution in the market. They publish a quarterly newsletter,
NAHSA News, and an annual Industry Calendar.
American Agricultural Economics Association (AAEA)
1110 Buckeye Ave. Members: 4,500
Ames, IA 50010-8063 Staff: 6
Phone:515-233-3202
Fax:515-233-3101
The American Agricultural Economics Association, founded in 1910, is a
professional society of state, federal, and industrial agricultural economists,
teachers, and extension workers. The AAEA works to further knowledge of
agricultural economics through scientific research, instruction, publications,
meetings, and other activities. They publish a bimonthly newsletter, a semi-
bimonthly American Journal of Agricultural Economics, a quarterly
magazine Choices, and a biennial Handbook Directory.
Institute for Agriculture and Trade Policy (LATP)
1313 5th St., SE, No. 303
Minneapolis, MN 55414
Phone:612-379-5980
Fax: 612-379-5982
The IATP was founded in 1986 and has an annual budget of $1.15 million.
They maintain a speakers bureau and conduct research programs on trade
agriculture, global institutions, North-South relations, and the Third World.
They publish several periodical bulletins.
California Fertilizers Association (CFA)
17001 St., Ste. 130
Sacramento, CA 95814
Phone: 916-441-1584
Fax: 916-441-2569
The CFA represents fertilizer manufacturers, distributors, wholesalers, and
retail dealers that sell products within California. They maintain a legislative
hotline and publish studies and handbooks on issues pertaining to fertilizers.
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American Society of Agronomy (ASA)
677 S. Segoe Rd.
Madison, WI 53711
Phone: 608-273-8080
Fax: (608) 273-2021
Members: 12,500
Staff: 30
The ASA was founded in 1907 and presently operates on a budget of 2.5
million dollars per year. ASA is a professional society of plant breeders, soil
scientists, chemists, educators, technicians, and other concerned with crop
production and soil management. ASA sponsors fellowship programs and
provides placement service. ASA publishes annual, bimonthly, and monthly
periodicals as well as special publications.
Potash and Phosphate Institute (PPI)
655 Engineering Drive No. 110
Norcrdss, GA 30092
Phone: 770-447-0335
Fax: 770-448-0439
Members: 14
Staff: 30
PPI supports scientific research in the areas of soil fertility, soil testing, plant
analysis, and tissue testing. PPI participates in farmers meetings, workshops,
and training courses and publish a quarterly magazine, Better Crops -with
Plant Food.
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Contacts and References
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS
For further information on selected topics within the Fertilizer, Pesticide, and Agricultural Chemical
Industry, a list of contacts and publications are provided below.
Contacts6
Name
Michelle C. Yaras
Arty Williams
Jean Frane
Paul Parsons
David Stangel
Joseph Hogue
Robert McNally
Joseph Nevola
Ellen Kramer
Carol Peterson
Robert A. Forrest
Nancy Fitz
Cathleen Barnes
John MacDonald
Kevin Keaney
Organization
EPA, Office of Enforcement and
Compliance Assurance (OECA),
Agriculture and Ecosystems Division,
Agriculture Branch
EPA, Office of Prevention, Pesticides
and Toxic Substances (OPPT)
EPA, OPPT
EPA, OPPT
EPA, OECA
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
EPA, OPPT
Telephone
202 564-4153
703 305-5239
703 305-5944
703 308-9073
202564-4162
703 308-9072
703 308-8085
703 308-8037
703 305-6475
703 305-6598
703 308-9376
703 305-7385
703 305-7101
703 305-7370
703305-5557 .
Subject
Notebook Contact
Ground Water Pesticide
Management Plan Rule
Food Quality Protection Act
FIFRA Data Requirements
Stored or Suspended
Pesticides; Good Laboratory
Practice Standards; Pesticide
Management and Disposal
FIFRA
Restricted Use
Classifications
FIFRA Pesticide Tolerances
FIFRA Pesticide Tolerances
FIFRA Pesticide Tolerances
FIFRA Tolerance Fee
Structure
FIFRA Exemptions
FIFRA Pesticide
Management and Disposal -
FIFRA Prior Informed
Consent
Certification and Training
FIFRA Worker Protection
Standards
The following people received a draft copy of this Sector Notebook and may have provided
6 Many of the contacts listed above have provided valuable information and comments during the development of
this document. EPA appreciates this support and acknowledges that the individuals listed do not necessarily
endorse all statements made within this notebook.
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Agricultural Chemical Industry
Contacts and References
comments.
Name
Paul Bangser
Philip J. Ross
Don Olson, Chief
Jon Jacobs
Jerry Stubbs
Anne E. Lindsay,
Director
Marcia E. Mulkey,
Director
Artie Williams,
Chief
Seth Heminway
Sam Silverman
Laura Livingston
Samantha Fairchild
Sherri Fields
Tinka Hyde
Robert Lawrence
Diane Callier
Mike Gaydosh
Jo-Ann Semones
Ron Kreizenbeck
Edward M. White
Organization
EPA, Office of General Counsel, Water Division
EPA, Office of General Counsel, Pesticides and Toxic
Substances Division
EPA, Industrial Branch, OECA, Office of Regulatory
Enforcement, Water Enforcement -Division
EPA, OECA, Office of Regulatory Enforcement, Case
Development,, Policy and Enforcement Branch -Eastern
Regions, Toxics and Pesticides Enforcement Division
EPA, Case Development, Policy and Enforcement Branch-
Western Regions, Toxics and Pesticides Enforcement
Division, Office of Regulatory Enforcement
EPA, Field and External Affairs Division
Office of Pesticide Programs
EPA, Office of Pesticide Programs
EPA, Environmental Field Branch, Field and External
Affairs Division, Office of Pesticide Programs
EPA, OC Sector Notebook Coordinator
EPA, Enforcement Coordinator
Region 1
EPA, Enforcement Coordinator
Region 2
EPA, Enforcement Coordinator
Region 3
EPA, Enforcement Coordinator
Region 4
EPA, EPA, Enforcement Coordinator
Region 5
EPA, Enforcement Coordinator
Region 6
EPA, Enforcement Coordinator
Region 7
EPA, Enforcement Coordinator
Region 8
EPA, Enforcement Coordinator
Region 9
EPA, Enforcement Coordinator
Region 10
Assistant Pesticide Administrator, Indiana State Chemist
Office, Purdue University
Telephone
202 260-7630
202 260-0779
202 564-5558
202 564-4037
202 564-4178
703 305-5265
703 305-7090
703 305-5239
202 564-7017
617 565-3443
212 637-4059
215 814-5710
404 562-9684
312886-9296
214 665-6580
913 551-7459
303312-6773
415 744-1547
206 553-1265
765 494-1587
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Agricultural Chemical Industry
Contacts and References
Dale Dubberly, Chief
Robin Rosenbaum
Buzz Vance
Donnie Dippel
Paul Kindinger
Joel Padmore
Renee Pinel
Mark Muller
Rick Kirchhoff
Robert Rosenberg
Robert E. Roberts
Diane Bateman
Jay Vroom
Bureau of Compliance Monitoring
Florida Department of Agriculture & Consumer Services
Pesticide Registration Manager, Pesticide & Plant Pest
Management Division, Michigan Department of
Agriculture
Nebraska Department of Agriculture
Assistant Commissioner, Pesticide Programs, Texas
Department of Agriculture
Agricultural Retailers Association (ARA)
Association of American Plant Food Control Officials
(AAPFCO), Food & Drug Protection Division
North Carolina Department of Agriculture
California Fertilizers Association
Institute for Agriculture and Trade Policy
National Association of State Departments of Agriculture
(NASDA)
National Pest Control Association
Executive Director
Environmental Council of States (ECOS)
The Fertilizer Institute (TFI)
American Crop Protection Association
850488-8731
517335-6542
402 471-6853
512463-7476
314567-6655
919 733-7366
916 441-1584
612 870-3420
202 296-9680
703 573-8330
202 624-3660
202 675-8250
202 296-1585
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Agricultural Chemical Industry
Contacts and References
Section II; Introduction to the Fertilizer, Pesticide, and Agricultural Chemical Industry
1992 Census of Manufacturers Industry Series: Agricultural Chemicals, United States Department
of Commerce, Bureau of Census, Economics and Statistics Administration, Washington, DC, May
1995.
1987 Standard Industrial Classification Manual, Office of Management and Budget, 1987.
Aspelin, Arnold, Pesticide Industry Sales and Usage, 1994 and 1995 Market Estimates, Office of
Prevention, Pesticides and Toxic Substances, USEPA, August 1997.
"Facts and Figures for the Chemical Industry," Chemical and Engineering News, June 23, 1998.
Hodge, Charles A. and Popovici, Neculai N., ed., Pollution Control in Fertilizer Production, Marcel
Dekker, Inc., 1994.
Hoffineister, George. "Fertilizers", Kirk-Othmer Encyclopedia of Chemical Technology, 4th ed. New
York: John Wiley & Sons. 1993.
Kent, James A., ed., Riegel's Handbook of Industrial Chemistry, Ninth edition, Van Nostrand
Reinhold,Nevv York, 1992.
Ollinger, Michael, and Fernandez-Cornejo, Jorge. Regulation, Innovation, and Market Structure in
the United States Pesticide Industry, Economic Research Service, USD A, June 1995.
Andrilenas, Paul, and Vroomen, Harry. United States Department of Agriculture, Seven Farm Input
Industries, Fertilizer, Economic Research Service, U.S.D.A., September 1990.
Dun & Bradstreef s Million Dollar Directory, 1997.
United Nations Environment Programme and United Nations Industrial Development Organization,
Mineral Fertilizer Production and the Environment, UNEP, Paris, 1996.
United States Environmental Protection Agency, Enforcement, Planning, Targeting & Data
Division,, FIFRA, section 7 Data System, United States EPA. 1996.
United States Environmental Protection Agency, Development Document for Best Available
Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide
Formicating, Packaging, and Repackaging Industry- Final, EPA, Office of Water, Washington, DC,
September 1996.
United States Environmental Protection Agency, Biopesticides Web Site, Office of Pesticide
Programs, , August 1999.
United States Environmental Protection Agency, Compilation of Air Pollutant Emission Factors
(AP-42), Fifth edition, EPA, Office of Air Quality Planning and Standards, Research Triangle Park,
Sector Notebook Project
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Agricultural Chemical Industry
Contacts and References
NC, July 1993.
United States Environmental Protection Agency, Guides to Pollution Prevention, The Pesticide
Formulating Industry, EPA, Center for Environmental Research Information, Cincinnati, February
1990.
United States Industry & Trade Outlook '98, United States Department of Commerce, International
Trade Administration, Washington, DC, 1998.
United States International Trade Commission, Industry & Trade Summary, Pesticide Products and
Formulations, USITC Publication 2750, Office of Industries, March 1994.
Section III; Industrial Process Description
Air and Waste Management Association, Buonicore, Anthony J. and Davis, Wayne T., ed., Air
Pollution Engineering Manual, Van Nostrand Reinhold, New York, 1992.
Cremlyn, R., Pesticides, John Wiley & Sons, New York, 1978.
Hargett, Norman and Pay, Ralph, "Retail Marketing of Fertilizers in the United States" Presented
at the Fertilizer Industry Round Table, Atlanta, Georgia, 1980.
Hoffmeister, George. "Fertilizers", Kirk-Othmer Encyclopedia of Chemical Technology, 4th ed.
Volume 10, New York: John Wiley & Sons. 1993.
Kroschwitz, Jacqueline, and Howe-Grant, Mary (eds.). "Ammonia", Kirk-Othmer Encyclopedia of
Chemical Technology, 4th ed. Volume 2, New York: John Wiley & Sons. 1992:
Hodge, Charles A. and Popovici, Neculai N., ed., Pollution Control in Fertilizer Production, Marcel
Dekker, Inc., 1994.
Kent, James A., ed., Riegel's Handbook of Industrial Chemistry, Ninth edition, Van Nostrand
Reinhold, New York, 1992.
Korcak, R.F. "Utilization of Coal Combustion By-Products in Agriculture and Horticulture,"
Agricultural Utilization of Urban and Industrial By-Products, American Society of Agronomy,
Madison, WI, 1995.
Lewis, Richard J., Sr., ed., Hawley's Condensed Chemical Dictionary, Twelfth edition, Van
Nostrand Reinhold, New York, 1993.
Manual on Fertilizer Statistics, Food and Agriculture Organization of the United Nations, Rome,
1991.
Miller, W.P. "Environmental Considerations in Land Application of By-Product Gypsum,"
Agricultural Utilization of Urban and Industrial By-Products, American Society of Agronomy,
Madison, WI, 1995.
Sector Notebook Project
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Agricultural Chemical Industry
Contacts and References
Nielson, Francis T., Manual of Fertilizer Processing, Marcel Dekker, Inc., New York, 1987.
The Fertilizer Institute (TFI), comments submitted by Jim Skillen on a draft of this Sector Notebook,
September 1999.
United Nations Environment Programme, Mineral Fertilizer Production and the Environment,
Technical Report N.26, United Nations Industrial Development Organization, 1996.
United States Environmental Protection Agency, Compilation of Air Pollutant Emission Factors
(AP-42), Fifth edition, EPA, Office of Air Quality Planning and Standards,.Research Triangle Park,
NC, July 1993a.
United States Environmental Protection Agency, Development Document for Best Available
Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide
Formulating, Packaging, and Repackaging Industry-Final, EPA, Office of Water, Washington, DC,
September 1996.
United States Environmental Protection Agency, Development Document for Effluent Limitations
Guidelines and New Source Performance Standards for the Basic Fertilizer Chemicals Segment of
the Fertilizer Manufacturing Point Source Category, EPA, Office of Air and Water Programs,
Washington, DC, March 1974.
United States Environmental Protection Agency, Guides to Pollution Prevention, The Pesticide
Formulating Industry, Risk Reduction Engineering Laboratory and Center for Environmental
Research Information, Office of Research and Development, February 1990.
United States Environmental Protection Agency, Pesticide Industry Sales and Usage, 1994 and 1995
Market Estimates, Office of Prevention, Pesticides and Toxic Substances, August 1997.
United States Environmental Protection Agency, Report to Congress for Cement Kiln Dust. Volume
II: Methods and Findings. Springfield, VA: United States Department of Commerce, December
1993b.
United States Environmental Protection Agency, 1996 Toxics Release Inventory Database.
Water Environment Federation, Pretreatment of Industrial Wastes, Manual of Practice FD-3,
Alexandria, VA, 1994.
Section IV; Chemical Release and Transfer Profile
United States Environmental Protection Agency, 1996 Toxics Release Inventory Database.
United States Environmental Protection Agency, 1995 Toxics Release Inventory Database.
United States EPA Office of Air and Radiation, AIRS Database, 1997.
Sector Notebook Project
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Agricultural Chemical Industry
Contacts and References
United States Environmental Protection Agency, 1995 Toxics Release Inventory Public Data
Release, United States EPA Office of Pollution Prevention and Toxics, April 1997. (EPA 745-R-97-
005)
Section V: Pollution Prevention Opportunities
California Fertilizer Association, Dry and Liquid Fertilizer Handling Guidelines/or Retail Fertilizer
Facilities, CFA, http://www.calfertilizer.org/fertguide.html, November 1996.
Hunt, Gary, et. al., eds. Case Summaries of Waste Reduction by Industries in the Southeast. Waste
Reduction Resource Center for the Southeast, North Carolina department of Natural Resources and
Community Development, Raleigh, NC, July 1989.
Preventing Pollution in the Chemical Industry, Five Years of Progress, Chemical Manufacturers
Association, 1993.
United Nations Environment Programme, Mineral Fertilizer' Production and the Environment,
Technical Report N.26, United Nations Industrial Development Organization, 1996.
United States Environmental Protection Agency, Development Document for Best Available
Technology, Pretreatment Technology, and New Source Performance Technology for the Pesticide
Formulating, Packaging, and Repackaging Industry- Final, EPA, Office of Water, Washington, DC,
September 1996.
United States Environmental Protection Agency, Guides to Pollution Prevention, The Pesticide
Formulating Industry, EPA, Center for Environmental Research Information, Cincinnati, February
1990.
Section VI; Summary of Applicable Federal Statutes and Regulations
Haugrud, K. Jack. "Agriculture," Chapter 8 in Sustainable Environmental Law, Integrating Natural
Resource and Pollution Abatement Law from Resources to Recovery, Environmental Law Institute,
St. Paul, 1993.
Landfair, Stanley W. "Toxic Substances Control Act," Chapter 11 in Environmental Law Handbook,
12th ed., Government Institutes, Inc., Rockville, MD, 1993.
Miller, Marshall E. "Federal Regulation of Pesticides," Chapter 13 in Environmental Law
Handbook, 12th ed., Government Institutes, Inc., Rockville, MD, 1993.
Section VII: Compliance and Enforcement History '
United States Environmental Protection Agency, Data obtained from EPA's Integrated Data for
Enforcement Analysis (IDEA) system in 1997.
Sector Notebook Project
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Agricultural Chemical Industry
Contacts and References
Section VIII; Compliance Activities and Initiatives
Agricultural Retailers Association, Retailer Facts by FAX, ARA Weekly, November 7,1997.
Center for Environmental and Regulatory Information Services,
Jaszczak, Sandra, ed. Gale Encyclopedia of Associations. 31st ed., International Thomson
Publishing Co., 1996.
United States Environmental Protection Agency, 33/50 Program Office, 1997.
Sector Notebook Project
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